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MIRAMAR LAKE HOMEOWNERS ASSOCIATION INC. 4:18‐CV‐00851
Plaintiff
vs.
ELIZABETH THOMAS,
Defendant
____________________________________________________________________________________
EMERGENCY MOTION FOR ORDER TO SHOW CAUSE
EMERGENCY MOTION FOR RELIEF PURUSANT
TO FED. R. CIV. P. 60(b)(4)
______________________________________________________________________________
TO THE HONORABLE JUDGE OF SAID COURT:
Defendant Elizabeth Thomas, her prior legal representatives Attorney James M.
Andersen and Attorney Colleen M. McClure, hereby file this Emergency Motion To Hold
Stewart Title Company, Primary Residential Mortgage Inc., the Meritage Parties and MTH
Lending Group L.P.., in Civil Contempt” for the failure to obey orders entered by this
Court on June 25, 2018, and January 31, 2019, (the “Orders”) [Docket Nos. 3 and 79], and
Emergency Motion for Relief pursuant to Fed. R. Civ. P. 60(b)(4). In support of this
Motion states:
I. ORDER TO SHOW CAUSE
1. Almost one year ago on June 25, 2018, this Court issued is first denial of a
remand order [Docket No. 3], for the cases case entitled James Allen el, al. vs. MTH
Lending Group L.P., et al., under cause No. 2017‐76078: Elizabeth Thomas et al, vs.
Michael J. Pizzitola Jr., et al., under caused No. 2017‐82388, to be remanded back to the
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127thJudicial District Court, Harris County Texas. This denial is based on the fact that the
Court had already effectuated a remand order remanding this cause number No. 18‐cv‐
00851 in its entirely to the 333rd Judicial District Court, Harris County Texas. Still
Defendant who has moved on is still being subjected to various tricks and schemes of the
opposing parties.
2. On January 31, 2019, this Court issued its second denial of a remand order
[Docket No. 79], in response to Stewart Title Company November 29, 2018,
“Reconsideration Remand Motion” [Docket No. 58], which sought remand order for the
case entitled James Allen el, al. vs. MTH Lending Group L.P., et al., under cause No. 2017‐
76078 and the Meritage Parties Joiner in Stewart Title Company which sought a remand
order for the case Elizabeth Thomas et al, vs. Michael J. Pizzitola Jr., et al., under caused
No. 2017‐82388, each sought an order that these cases be remanded back to the 127th
Judicial District Court, Harris County Texas, which again this court denied remand on
the grounds that on June 25, 2018, the court had already effectuated a remand order
remanding this cause number No. 18‐cv‐00851 in its entirely to the 333rd Judicial District
Court, Harris County Texas.
3. The Honorable Judge Miller on October 31, 2018, also issued an order ruling
that these two (2) cases mention above have already been subject to a June 25, 2018,
remand order remanding cause number No. 18‐cv‐00851 in its entirely to the 333rd
Judicial District Court, Harris County Texas. See Exhibit A and B Attached hereto.
4. Again as recently as April 16, 2019, in the case entitled Primary Residential
Mortgage Inc., and Meritage Homes of Texas LLC., vs. Elizabeth Thomas et al, in cause no.
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2018‐91506 this Court ruled that the cases Elizabeth Thomas et al, vs. Michael J. Pizzitola
Jr., et al., under caused No. 2017‐82388, and James Allen el, al. vs. MTH Lending Group
L.P., et al., under cause No. 2017‐76078: were denied prior remand order because on June
the court had already effectuated a remand order remanding this cause number No. 18‐
cv‐00851 in its entirely to the 333rd Judicial District Court, Harris County Texas. See
Exhibit C Attached hereto.
5. Five federal court denial of remands all of which clearly states that the cases
James Allen el, al. vs. MTH Lending Group L.P., et al., under cause No. 2017‐76078: and
Elizabeth Thomas et al, vs. Michael J. Pizzitola Jr., et al., under caused No. 2017‐82388,
were not remand back to the 127th Judicial District Court, Harris County Texas, instead
this case are associated with cause number No. 18‐cv‐00851 and was remanded in its
entirely to the 333rd Judicial District Court, Harris County Texas. These court order
clearly evidence that these cases are no longer assigned to the 127th Judicial District Court,
Harris County Texas per court denial of remand orders any defects in this order is not
reviewable.
6. Despite numerous denials of remand orders and the fact that said cases are
not longer 127th Judicial District Court, Harris County Texas, the opposing parties avers
that they are not bound by this court orders as such continue to devise various
fraudulent and illegal even criminal schemes to get said case back into the 127th District
Court despite this court repeated denials.
7. The new trick: On April 16, 2019, a remand order was issued for a
different case entitled Primarily Residential Mortgage Inc., and Meritage Homes of Texas
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LLC., vs. Elizabeth Thomas et al, in cause no. 2018‐91506 that was removed to Federal
court from the 127th District Court on February 19, 2019, See Exhibit D Attached hereto.,
This case was remanded back to the 127th District Court on April 17, 2019. See Exhibit E
Attached hereto.
8. On April 16, 2019, counsel for the Meritage Homes of Texas LLC., fraudulently
attempted to file the remand order for the case entitled Primary Residential Mortgage
Inc., Meritage Homes of Texas LLC., vs. Elizabeth Thomas, James Allen and Robert L.
Thomas, under Cause No. 2018‐91506; instead into the James Allen el, al. vs. MTH
Lending Group L.P., et al., under cause No. 2017‐76078, in order to reinstate this case that
was already denied a remand order on January 31, 2019. See: Exhibit F Attached hereto
Envelope number 32822449”, which is a copy of Judge Hittner’s Remand Order.
th
9. On April 16, 2019, the 127 District Clerk of Court Devanshi Patel rejected and
refused the filing and returned it on grounds that the “Remand Order” has the
resubmit and include cause number, “style” and” court” signed. DP. See: Exhibit G
Attached hereto. This denial is also based on the fact that per federal court orders this
case is no longer assigned or pending in the 127th District Court.
10. Judge Hittner’s Case Manager, Ellen Alexander, has confirmed that on April
17, 2019, that she merely printed a copy of the “original remand order” for the case
entitled Primarily Residential Mortgage Inc., and Meritage Homes of Texas LLC., vs.
Elizabeth Thomas et al, in cause no. 2018‐91506 certified it and mailed via FedEx to the
Clerk of the 127th District Court overnight express mail which was delivered on April 17,
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2019, and signed by S. Prince (an assistant clerk for the Harris County District Clerk). See
Exhibit H Attached hereto.
11. On April 22, 2019, the certified copy of the April 16, 2019, remand order for the
case entitled Primarily Residential Mortgage Inc., and Meritage Homes of Texas LLC., vs.
Elizabeth Thomas et al, in cause no. 2018‐91506 has been altered with by some unknown
person or clerk in the 127th District Court who has fraudulently “written in bold letters
across the top of this remand order cause No. “2017‐76078” and the “127th District Court.”
See: Exhibit I Attached hereto.
12. This April 16, 2019, altered remand order gives the false appearance that Judge
Hittner, U.S.D.J., had himself changed the cause number so as to remand the case
entitled James Allen el, al. vs. MTH Lending Group L.P., et al., under cause No. 2017‐76078,
back to the 127th District Court; instead of the case entitled Primarily Residential
Mortgage Inc., and Meritage Homes of Texas LLC., vs. Elizabeth Thomas et al, in cause no.
2018‐91506 which is sole single case that was before this court.
13. Only a “federal district judge” can issue a remand order. Orders granting
remand motions back to state court are “dispositive” and can only be ordered by a United
States District Judge not some unknown person, in State Court who in this case altered
this order as issued for a different case. See Vogul v. U.S. Office Prods. Co., 258 F.3d 509,
515 (6th Cir. 2001) (holding that remand orders are “dispositive” and can only be entered
by a district judge because “a remand motion has the same functional effect as dispositive
motions enumerated in § 636(b)(1)(A)”); In re U.S. Healthcare, 159 F.3d 142, 146 (3rd Cir.
1998) (holding that a remand order was dispositive because it “banishes the entire case
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from the federal court”).
14. Contempt of court is defined as any act which is calculated to embarrass,
hinder, or obstruct a court in the administration of justice, or which is calculated to
lessen the authority or dignity of a court. Black’s Law Dictionary 288 (5th ed. 1979).
Judicial authority to cite an individual for contempt of court is as old as the courts
themselves. Ex parte Robinson, 86 U.S. (19 Wall) 505, 510 (1873)(“The moment the courts
of the United States were called into existence and invested with jurisdiction over any
subject, they became possessed of this power [i.e., the contempt power].”).
15. Moreover, the power to punish acts of contempt has been recognized as
inherent in all courts. Chambers v. NASCO, Inc., 501 U.S. 32 (1991); accord Roadway
Express, Inc. v. Piper, 447 U.S. 752, 764 (1980); Green v. United States, 356 U.S. 165
(1958); Gompers v. Buck’s Stove & Range Co., 221 U.S. 418 (1911); United States v. Shipp, 203
U.S. 563 (1906); In re Terry, 128 U.S. 289 (1888); Ex parte Robinson, 86 U.S. (19 Wall.) 505
(1873); Anderson v. Dunn, 19 U.S. (6 Wheat) 204 (1821).
16. This inherent authority originates from the necessity for enforcing court orders
and judgments, as well as maintaining basic order in the courtroom. “For this reason,
‘Courts of justice are universally acknowledged to be vested, by their very creation, with
power to impose silence, respect and decorum, in their present, and submission to their
lawful mandates.'22 Chambers v. NASCO, INC., 501 U.S. 32, 43 (1991)(quoting Anderson v.
Dunn, 19 U.S. (6 Wheat) 204, 227 (1821).
17. Despite the Court numerous denial of remand orders which evidences that
the said cases ARE NOT pending in the 127th District Court Stewart Title Company, MTH
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Lending Group L.P., the Meritage Parties and Primary Residential Mortgage Inc, has
commence to serve defendants with pleadings from the 127th District Court in the
case“2017‐76078” a case under the false pretense that on or about April 17, 2019, Judge
Hittner himself altered an remand order issued for another case entitled Primary
Residential Mortgage Inc., and Meritage Homes of Texas LLC., vs. Elizabeth Thomas et al,
in cause no. 2018‐9150 “by writing in bold letters across the top of the remand order cause
No. “2017‐76078” and the “127th District Court” and remanded this case back to the 127th
District Court (initially remanded to the 333rd District Court); instead. This is not the
first time these parties have manufactured fake orders and illegally used a federal court
judge name.
WHEREFORE, Defendants, individually and jointly, seeks the Court to issue a Order
to Cause as to why Stewart Title Company, the Meritage Parties, Primary Residential
Mortgage Inc., and MTH Lending Group L.P, should not be held in Civil Contempt for
refusing to obey Orders issued by this Court; Upon investigation and confirmation, the
Deputy Clerk of this court denies the “Court” altered the certified copy of the remand
order for the case entitled Primary Residential Mortgage Inc., and Meritage Homes of
Texas LLC., vs. Elizabeth Thomas et al, in cause no. 2018‐91506, by hand writing on the
order the case No. 2017‐76078 : to reflect that this case was instead being remanded to
the 127th District Court.
II. Motion for relief pursuant to Fed. R. Civ. P. 60(b)(4) .
Defendant Elizabeth Thomas and her prior legal representatives Attorney James
M. Andersen and Attorney Colleen M. McClure, states that this motion is timely as it
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challenges a remand order issued on April 16, 2019. The Defendants have a meritorious
defense in this action, is based on an occurrence that recently transpired on or about
April 17, 2019 and this issued has never been raised before this court before.
Defendants alleges that on April 16, 2019, this Court in the case entitled Primary
Residential Mortgage Inc., and Meritage Homes of Texas LLC., vs. Elizabeth Thomas et al,
in cause no. 2018‐91506: issued remanded order remanding this case back to the 127th
Judicial District Court; and
On April 16, 2019, Counsel for Meritage Homes of Texas LLC., fraudulently
attempted to file Primary remand order instead into the case entitled James Allen el, al.
vs. MTH Lending Group L.P., et al., under cause No. 2017‐76078. The 127th District Clerk
of Court rejected and returned the filings on the ground that (i) incorrect/incomplete
info: Resubmit using correct “cause number”. Please resubmit and include cause
number, “style” and” court” signed. DP, and (ii) filed into the case is a copy of this Court
January 31, 2019, denial of remand order which clarifies that cause No. 2017‐76078 is
associated with federal cause No. 4;18‐cv‐00851 and was remanded in its entirety to the
333rd Judicial District Court per court order on June 25, 2018 instead of 127th District Court.
On April 17, 2019, this Court Case Manager, Ellen Alexander, confirmed that on
April 17, 2019, that she merely printed a copy of the “original remand order” for the case
entitled Primarily Residential Mortgage Inc., and Meritage Homes of Texas LLC., vs.
Elizabeth Thomas et al, in cause no. 2018‐91506 certified it and mailed via FedEx to the
Clerk of the 127th District Court overnight express mail which was delivered on April 17,
2019, and signed by S. Prince (an assistant clerk for the Harris County District Clerk).
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Defendants alleged that on or about April 22, 2019, upon District Clerk in the 127th
District Court receipt of the certified copy of the April 16, 2019, remand order for the case
entitled Primary Residential Mortgage Inc., and Meritage Homes of Texas LLC., vs.
Elizabeth Thomas et al, under cause no. 2018‐91506 it was fraudulently altered by some
unknown person or clerk who fraudulently “wrote in bold letters across the top of the
remand order the cause No. “2017‐76078” and the “127th District Court” thereby
reinstating this case instead of the case entitled Primary Residential Mortgage Inc., and
Meritage Homes of Texas LLC., vs. Elizabeth Thomas et al, under cause no. 2018‐91506.
Opposing Parties are alleging that the Honorable Judge Hittner, U.S.D.J., himself on
or about April 17, 2019, had written in bold letters across the top of this remand order cause
No. “2017‐76078” and the “127th District Court” after a review of his prior January 31, 2019,
denial of remand order and decided to set aside and reverse his prior remand order
himself and remand this case instead to the 127th District Court.
The Opposing parties would not be unfairly prejudiced by this motion. See;
National Credit Union Admin. Bd. v. Gray, 1 F.3d 262, 264 (4th Cir.1993) (quoting Park
Corp. v. Lexington Ins. Co., 812 F.2d 894, 896 (4th Cir.1987)). As review of a prior remand
order is prohibited by law and reversal is not possible.
circumstances," which has occurred on or about April 17, 2019, in regard to a new alleged
remand order allegedly issued by the Honorable Judge Hittner whom according to
Opposing Parties has reviewed his prior June 25, 2018 {Docket Nos. 3and 79] denial of a
remand orders and decided to reverse the remand order and set them aside by issuing a
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new remand on order remanding the cases entitled Elizabeth Thomas et al, vs. Michael J.
Pizzitola Jr., et al., under caused No. 2017‐82388 and James Allen el, al. vs. MTH Lending
Group L.P., et al., under cause No. 2017‐76078, back to the 127th District State Court. See,
e.g., Werner v. Carbo, 731 F.2d 204, 207 (4th Cir.1984).
Defendants argue that the Court would lack jurisdiction to review its prior remand
order and that upon information and belief the Honorable Judge Hittner never himself
“wrote in bold letters across the top of April 16, 2019, remand order the cause No. “2017‐
76078” and the “127th District Court” thereby reinstating this case instead of the case
entitled Primarily Residential Mortgage Inc., and Meritage Homes of Texas LLC., vs.
Elizabeth Thomas et al, under cause no. 2018‐91506. As such this remand order is void as
to the Defendant.
At Issue: Federal case law supports that review of denial of a remand order is
clearly prohibited by law as is clearly set forth in 28 U.S.C. § 1447(d). This Court prior
remand order by law cannot be undone, or set aside. The April 16, 2019, fraudulently
altered remand order was not issued by the Judge Hittner as a means to, set aside or
reverse his prior June 25, 208, and January 31, 2019, [Docket No. 3 and79], denial of a
remand order and would lack subject matter jurisdiction to review a prior denial of a
remand order.
II. LEGAL STANDARD OF REVIEW
On motion and just terms, the court may relieve a party or its legal representative
from a final judgment, order, or proceeding [because among other] reasons . . . the
judgment or order is void." FED R. CIV. P. 60(b)(4) . The Fifth Circuit has "recognized
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two circumstances in which a judgment or order may be set aside under Rule 60(b): [1] if
the initial court lacked subject matter or personal jurisdiction; and/or [2] if the district
court acted in a manner inconsistent with due process of law." Callon Petroleum Co. v.
Frontier Ins. Co., 351 F.3d 204, 208 (5th Cir. 2003) (citing Jackson v. FIE Corp., 302 F.3d 515,
521‐22 (5th Cir. 2002); Carter v. Fenner, 136 F.3d 1000, 1005 (5th Cir. 1998)).
A. Lack of Subject Matter Jurisdiction
Fed. R. Civ. P. 60(b)(4) motions leave no margin for consideration of the district
court’s discretion as the judgments or orders themselves are by definition either legal
nullities or not.” Carter v. Fenner, 136 F.3d 1000, 1005 (5th Cir. 1998.)"
Defendants Elizabeth Thomas and her prior legal representatives Attorney James M.
Andersen and Attorney Colleen M. McClure, challenges that the April 16, 2019, remand
order issued in and for another case entitled Primarily Residential Mortgage Inc., and
Meritage Homes of Texas LLC., vs. Elizabeth Thomas et al, under cause no. 2018‐91506 is
void ab initio as to case entitled cause No. “2017‐7607” on grounds that (i) the April 16,
2019 is a forgery that has been fraudulently altered and was not endorsed by Judge
Hittner and (ii) the honorable Judge Hittner would lack subject matter jurisdiction to
review his prior remand order.
A District Court can’t review its own remand order as it loses power and jurisdiction
to reconsider once remand is effectuated. See, Agostini v. Piper Aircraft Corp., 729 F.3d
350, 355‐56 (3d Cir. 2013) 28 U.S.C. section 1447(d) which bars district court from
reconsidering remand upon issuance of remand order. E.g., New Orleans Public Service,
Inc. v. Majoue, 802 F.2d 166, 168 (5th Cir. 1986); In re Lowe, 102 F.3d 731, 734 (4th Cir.
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1996). Also, the State District Court clearly has no authority to change or alter this
federal order.
The U.S. Supreme Court’s decision in City of Waco v. United States Fidelity and
Guaranty Co., 293 U.S. 140 (1934), underscores that once a case has been remanded to
state court that remand order cannot be undone. Significantly, the Waco Court
explained that a district court has no jurisdiction to reconsider a remand order as the
remand order to state court is the event that formally transfers jurisdiction from a district
court to a state court. See also Powerex Corp. v. Reliant Energy Services, Inc., 551 U.S. 224,
127 S.Ct. 2411, 2419, 168 L.Ed.2d 112 (2007) (stating that the City of Waco Court "cautioned
that the remand order itself could not be set aside").
The U.S. Supreme Court's reasoning in Powerex Corp. v. Reliant Energy Services,
Inc., 551 U.S. 224, 127 S.Ct. 2411, 2417, 168 L.Ed.2d 112 (2007). held that "when a district
remand is covered by 28 U.S.C. § 1447(c) and thus shielded from review by 28 U.S.C §
1447(d)." Id. In reaching this holding, the Court relied on the language of 28 U.S.C. §
1447(e).
On January 31, 2019, when this court denied and order remand that the cases
entitled James Allen el, al. vs. MTH Lending Group L.P., et al., under cause No. 2017‐76078
and Elizabeth Thomas et al, vs. Michael J. Pizzitola Jr., et al., under caused No. 2017‐82388,
be remanded back to the 127th District Court on the grounds that on June 25, 2018, it
relinquish its jurisdiction over this case H‐18‐0851 when the Court remanded it to the
333rd Judicial District Court, Harris County, Texas. After this court effectuated the June
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25, 2018, remand order this court closed this case and no longer retained subject matter
jurisdiction. Quaestor Investments, Inc., 997 S.W.2d at 228–29 (stating that a remand
from federal court to state court terminates the jurisdiction of the federal court over the
case and revests the state court with jurisdiction).
On its face, 28 U.S.C. § 1447(d) of the judicial code flatly prohibits review of
remand orders, by “appeal or otherwise” and section 1447(d) means what it says as the
court no longer has jurisdiction. Few statutes read more clearly than 28 U. S. C. ß1447(d):
An order remanding a case to the State court is not reviewable on appeal or otherwise . . .
That bar to appellate review is a venerable one, dating back to 1887, see Thermtron
Products, Inc. v. Hermansdorfer, 423 U. S. 336, 343 (1976). It is, moreover, not just
hortatory; it is jurisdictional. Things Remembered, Inc. v. Petrarca, 516 U. S. 124, 127, ñ128
(1995). 28 U.S.C. § 1447(c). Subsection (d) 28 U.S.C. § 1447 provides a bar to reviewing
remand orders: An order denying remand to the State court is not reviewable on appeal
or otherwise . . . . § 1447(d).
28 U.S.C. § 1447(d), provides that review of denial of a remand order is prohibited
by law on appeal or otherwise . . . . Otherwise includes fraudulently tampering and
altering a remand order designated for different case with a different caption, style, and
cause number i.e., Primarily Residential Mortgage Inc., and Meritage Homes of Texas LLC.,
vs. Elizabeth Thomas et al, in cause no. 2018‐91506 and fraudulently writing across the top
of the order the cause No. “2017‐76078” and the “127th District Court.” Under the false
pretense that the
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Indisputably, "otherwise" in § 1447(d) includes altered fake remands orders issued in
another case or reconsideration motions. See Three J Farms, 609 F.2d at 115
("Unquestionably, the statute not only forecloses appellate review, but also bars
reconsideration of such an order by the district court."); La Providencia, 406 F.2d at 253
("Both [district and appellate court review] are foreclosed; nothing could be more
inclusive than the phrase `on appeal or otherwise.'").
“Review is unavailable no matter how plain the legal error in ordering the remand.”
Briscoe v. Bell, 432 U.S. 404, 413‐14 (1977). Remand order cannot be reviewed even by the
SCOTUS on appeal or certiorari from final judgment in state court. E.g., Metropolitan
Cas. Ins. Co. v. Stevens, 312 U.S. 563, 568 (1941). Further, state courts are bound by this
Federal District Court's denial of remand order and must treat it as valid. See Resolution
Trust Corp. v. Warwick Nurseries, Ltd., 675 A.2d 730, 732 (Pa. Super. 1996) ("state courts
are bound by the judgment of federal courts" and must give federal proceedings full faith
and credit (citation omitted))
Defendant Elizabeth Thomas, her prior legal representatives Attorney James M.
Andersen and Attorney Colleen M. McClure, seeks an order to be relieved from any final
judgment, order, or proceedings presently being held in the 127th District State Court
associated with the cases under cause no. H‐18‐0851 as per this court order this case was
remanded to the 333rd Judicial District Court, Harris County, Texas (any defects is not
reviewable) and as such is not assigned or pending in the 127th District Court; and on
grounds that the Honorable Judge Hittner did not on April 17, 2019, issue a new remand
order which reverse and/or set it aside his prior denial of a remand orders {Docket Nos. 3
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and 79], indeed Judge Hittner would lack subject matter to do as such action would only
serve to circumvent the jurisdiction‐stripping function of § 1447(d).
CONCLUSION
representatives Attorney James M. Andersen and Attorney Colleen M. McClure, seeks an
order pursuant to Fed. R. Civ. P. 60(b) (4) to be relieved from all proceedings, motions,
orders, or judgments, post‐removal orders, filings, entered or being entered in the 127th
District Court in the cause No. “2017‐76078” on the grounds that this Court on April 16,
2019, did not issue any new remand order reversing or set aside its prior June 25, 2018, or
January 31, 2019, denial of remands orders by remanding this cause number to the 127th
District Court this order is void and whatever other relief the Court deems just and
proper in the premises.
Respectfully submitted,
COLLEEN M. McCLURE
ATTORNEY AT LAW
By: /s/ Colleen M. McClure
COLLEEN M. MCCLURE
Texas bar No. 24012121
4201 Cypress Creek Parkway, Suite 565
Houston, Texas, 77068
Tel. (281) 440‐1625
Fax. (281) 956‐4657
colleen.mcclure@att.net
By:/s/James M. Andersen
James M. Andersen
Texas State Bar No. 01165850
P. O. Box 58554
Webster, Texas 77598‐8554
Tel. (281)488‐2800
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Fax. (281)480‐4851
E‐Mail:jandersen.law@gmail.com
By/s/Elizabeth Thomas
Elizabeth Thomas Pro, Se
712 H St. NE Suite 1297
Washington DC., 20002
(832) 216‐8623
Tethomas3@aol.com.
CERTIFICATE OF CONFERENCE
Counsel attempted to contact opposing counsel to discuss this motion and the
emergency relief sought by phone prior to filing but was unsuccessful. Due to the
emergency nature of the relief sought this motion without a conference. Counsels are
available for a conference before the Court.
Certified to the 29th day of May, 2019
CERTIFICATE OF SERVICE
I certify that on May 29, 2019. the foregoing document was served on Counsel of
record via the Court’s ECF electronic notification system.
/s/Colleen M. McClure
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CERTIFICATE OF SERVICE AND CONFERENCE
I certify that May 29, 2019, a true and correct copy of the above Motion was served
to opposing counsel by email.
/s/ Colleen M. McClure_____________
Colleen M. McClure
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