Motion to Compel in VIRGINIA O. KINSEL, ET AL (RESTYLED PER ORDER 7/16/2020) vs ALICE LINDSEY PEACOCK, ET AL

On September 09, 2008 a PLTF'S MOT TO COMPEL PROD OF DOC BY J.LINDSEY&R.OL was filed involving a dispute between and for OTHER CIVIL, TEMP RESTRAINING ORDER/INJUNCTION in the District Court of Tarrant County.

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CAUSE NO. 153-232668-08 '0,~; .
~v
VIRGINIA 0. KINSEL, et al., § IN THE DISTRICT COURT OF~Y
§ ?:·~
Plaintiffs, § ~
§ ~
vs. § TARRANT COUNTY, TEXAS
§ e~
JANE 0. LINDSEY, et al., §
§
Defendants. § 153RD JUDICIAL DISTRICT

PLAINTIFFS' MOTION TO COMPEL PRODUCTION OF DOCUMENTS BY
DEFENDANTS JANE 0. LINDSEY AND ROBERT N. OLIVER

TO THE HONORABLE JUDGE OF SAID COURT:

NOW COME Plaintiffs VIRGINIA 0. KINSEL, AS EXECUTRIX OF THE ESTATE

OF J. FRANK KINSEL, J. FRANK KINSEL, JR., Individually, CAROLE K. EDWARDS,

Individually, CATHERINE K. COLLINS, Individually, ("Plaintiffs" or "Movants"), and file this

their Motion to Compel Defendants Jane 0. Lindsey and Robert N. Oliver to Answer Post-

Judgment Interrogatories, and, in support thereof, respectfully show unto the Court as follows:

Background Facts

1. Judgment in this cause was rendered for Plaintiffs against Defendants, Jackson

Walker, LLP, M. Keith Branyon, Jane 0. Lindsey and Robert N. Oliver on or about December

28, 2012.

2. On or about January 15, 2013, Plaintiffs propounded Post-Judgment

Interrogatories to Defendants Jane 0. Lindsey ("Lindsey") and Robert N. Oliver ("Oliver").

Lindsey and Oliver served their objections and responses to said Post-Judgment Interrogatories

on or about February 19, 2013. True and correct copies of Lindsey and Oliver's Post-Judgment

Interrogatory Responses are attached hereto as Exhibits "A" and "B", respectively, and

incorporated herein by reference for all purposes.
PLAINTIFFS' MOTION TO COMPEL PRODUCTION OF DOCUMENTS BY DEFENDANTS JANE 0. LINDSEY AND
ROBERTN. OLIVER-Page 1
!.'!.::..l'....:.in.sel\Lindaey\Motion • Compo~l PrO'DSEY AND
ROBERT N. OLIVER-Page S
Producdon.~
J_\LOJ\KinHI\Llndoey\MotlOII. Cornpet

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and

J. Lyndell Kirkley
Texas State Bar No. 11523000
Sean R. Looney
Texas State Bar No. 24050949
J. Edward Johnson
Texas State Bar No. 24070001
KIRKLEY & BERRYMAN, L.L.P.
100 N. Forest Park Blvd., Suite 220
Fort Worth, Texas 76102
Telephone: 817.335.3311
Facsimile: 817.335.7733
Attorneys for Plaintiffs
Virginia 0. Kinsel, et al.

PLAINTIFFS' MO'DON TO COMPEL PRODUCT!O).I OF DOCUMENTS BY DEFENDANTS JA.l\E 0. Ll':DSEY AND
ROBERT N. OLIVER-Page 6
Co:!'.peli'Toduction.~
J.'llnl\Kirla.EI'ILinclsey\Mo:ion •

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CERTIFICATE OF SERVICE

Ihereby certify that a true and correct copy of the foregoing has been served upon the
following in the manner specified below, this Zo...,.day of June, 2013:

Mr. J. Lyndell Kirkley Ms. Alison H. Moore
KIRKLEY & BERRYMAN, L.L.P. THOMPSON, COE, COUSINS & IRONS, L.L.P.
I 00 North Forest Park Blvd., Suite 220 700 North Pearl Street
Fort Worth, Texas 76102 25th Floor - Plaza of the Americas
Via Facsimi/e-(817) 335-7733 Dallas, Texas 75201
Via Facsimile---(114) 871-8109

Mr. William L. Kirkman Ms. Frances Garza, Pro Se
BOURLAND & KIRKMAN, L.L.P. 5435 FM 541
. ..201 Main Street, Suite 1400 McCoy, Texas 78113
Fort Worth, Texas 76102 Via First Class U.S. Mail
Via Facsimile-(817) 877-1863

Marshall M. Searcy, Jr. Ms. Ida Castillo
Frank P. Greenhaw IV 5437 FM 541
Kelly Hart & Hallman LLP McCoy, Texas 78113
201 Main Street, Suite 2500 Via First Class U.S. Mail
Fort Worth, Texas 76102
Via Facsimile---(817) 878-9280

Mr. Scott C. Kinsel
SCOTT C. KINSEL, P.C.
8708 South Congress, Suite B200
Austin, Texas 78745
Via Facslmile-(512) 628-3285

. '.' --·-
-' -

PLAINTIFFS' MOTION TO COMPEL PRODUCllON OF DOCUMENTS BY DEFENDANTS JANE 0. LINDSEY AND
ROBERT N. OLIVER-Page 7
J ILDJ\Kirae!\l.indsey\Motion. Compel Production.docx

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CAUSE NO. 153-232668-08

VIRGINIA 0. KINSEL, et a!., § IN THE DISTRICT COURT OF
§
§
vs. § TARRANT COUNTY, TEXAS
§
JANE 0. LINDSEY, eta!., § 153'd JUDICIAL DISTRICT

DEFENDANT JANE 0. LINDSEY'S OBJECTIONS AND RESPONSES
TO PLAINTIFFS' POST-JUDGMENT INTERROGATORIES

To: Plaintiffs, by and through their attorneys of record, Messrs. J.
Lyndell Kirkley and Sean R. Looney, Kirkley & Berryman, L.L.P.,
100 N. Forest Park Blvd., Suite 220, Fort Worth, Texas 76102; Mr.
Lindy D. Jones, Jones, Allen & Fuquay, L.L.P., 8828 Greenville
Ave., Dallas, Texas 75243; and Mr. Scott C. Kinsel, Scott C. Kinsel,
P.C., 8708 South Congress, Suite B200, Austin, Texas 78745.

Defendant Jane 0. Lindsey serves her Objections and Responses to Plaintiffs'
Post-Judgment Interrogatories as follows:

INTERROGATORY NO.1:

Please state your full legal name and any other name you have used at any time,
including each nickname, alias, and (if applicable) married name and name before your
marriage.

ANSWER:

Jane Oliver Lindsey.

INTERROGATORY NO.2:

Have you or your spouse filed an assumed name certificate or partnership
certificate? If so, for each certificate please state-

e. the full assumed or partnership name used;
b. the full name(s) of the person(s) (you, your spouse, or both) using it; and

Defendant Jane 0. Lindsey's Objections and Responses ~ ~ -'i~ •.-......
··--- -:'",)
to Plaintiffs' Post-Judgment Interrogatories Page I

WJ1 01 '13
EXHIBIT "A"

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c. the city, county, and state in which the assumed or partnership name was
primarily used.

ANSWER:

No.

INTERROGATORY NO.3:

Have you or your spouse used an assumed name or partnership name without
filing a certificate? If so, for each name please state--

a. the full assumed or partnership name used;
b. the full name(s) of the person(s) (you, your spouse, or both) using it; and
c. the city, county, and state in which the assumed or partnership name was
primarily used.

ANSWER:

No.

INTERROGATORY NO.4:

Please state your date and place of birth.

ANSWER:

March 13, 1924. Amarillo, Texas.

INTERROGATORY NO.5:

Please state your Social Security number.

ANSWER:

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the judgment by filing a Motion with the Court requesting that the Court set an
appropriate bond for the entire judgment, since the bond will involve both monetary and
non-monetary issues. See TEX. R. APP. P. 24.2. Consequently, once a supersedeas bond is
established by the Court, approved, and finalized, the information requested will not aid
in the enforcement of the judgment if the Motion for New Trial is denied. Lindsey
further objects to this Interrogatory because it seeks personal and private information.

liiTERROGATORY NO.6:

Please state the license number and issuing state of each driver's license in any of
your names.

ANSWER:

Lindsey objects to this Interrogatory because it seeks information that is not
relevant and not reasonably calculated to lead to the discovery of admissible evidence.
Lindsey has a filed a Motion for New Trial that has not yet been heard by the Court. It is
set for hearing on February 25, 2013. If the Court grants Lindsey's Motion, the
information requested is irrelevant, In the event the Court denies the Motion, the
Defendants- Ms. Lindsey, Mr. Oliver, and Jackson Walker, LLP, will seek to supersede
the judgment by filing a Motion with the Court requesting that the Court set an
appropriate bond for the entire judgment, since the bond will involve both monetary and
non-monetary issues. See TEX. R. APP. P. 24.2. Consequently, once a supersedeas bond is
established by the Court, approved, and finalized, the information requested will not aid
in the enforcement of the judgment if the Motion for New Trial is denied. Lindsey
further objects to this Interrogatory because it seeks personal and private information.

INTERROGATORY NO.7:

Please state each of your current residential addresses (street address, city, county,
state, zip code) and telephone numbers (including area code).

ANSWER:

5301 Bryant Irvin Road, #332, Fort Worth, Texas 76132.
(817) 924-3 879

Defendant Jane 0. Lindsey's Objections and Responses
to Plaintiffs' Post-Judgment Interrogatories Page 3

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IJ\'TERROGATORY NO.8:

Please state each of your current business addresses (street address, city, county,
state, zip cpde) and telephone numbers (including area code). Also please state any post
office box address used.

ANSWER:

NIA.

INTERROGATORY NO.9:

Are you now married? If you are, please state-

a. your spouse's full name; and
b. your spouse's complete present address.

ANSWER:

NIA.

INTERROGATORY NO. 10:

Have you been married to someone to whom you are not now married? If you
have, for each prior marriage please state-

a. whether the former spouse is still living;
b. the full present name of the former spouse if still living;
c. the date of the marriage;
d. the date the marriage ended and how it was terminated; and
e. the complete present residential address of the former spouse if still living.

ANSWER:

No.

INTERROGATORY NO. 11:

Is a suit to dissolve your marriage pending? If so, please state the cause number
and the name, number, and location of the court in which it is pending and, if you will do
so without a court order, attach a copy of any temporary order.
Defendant Jane 0. Lindsey's Objections and Responses
to Plaintiffs• Post-Judgment Interrogatories Page4

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ANSWER:

N/A.

INTERROGATORY N0.12:

Have you and your spouse ever partitioned your community property by written
agreement? If so, please state-

a. the date the agreement was signed;
b. the contents of the agreement, copying it verbatim or, if you will do so
without a court order, attaching a copy of the agreement to your answers;
and
c. whether the agreement has been filed in the records of any county and, if it
has, the name of each county in which it has been filed.

ANSWER:

No.

INTERROGATORY NO. 13:

Regarding your father, please state-

a. his full name;
b. whether he is now Jiving;
c. if he is alive, his complete present address;
d. if he is alive, his present occupation and employer's name; and
e. if he is not living, the date of his death and his complete residential address
when he died.

ANSWER:

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...--.

appropriate bond for the entire judgment, since the bond will involve both monetary and
non-monetary issues. See TEX. R. APP. P. 24.2. Consequently, once a supersedeas bond is
established by the Court, approved, and finalized, the information requested will not aid
in the enforcement of the judgment if the Motion for New Trial is denied.

INTERROGATORY N0.14:

Regarding your mother, please state-

a. her full name;
b. whether she is now Jiving;
c. if she is alive, her complete present address;
d. if she is alive, her present occupation and employer's name; and
e. if she is not Jiving, the date of her death and her complete residential
address when she died.

ANSWER:

Lindsey objects to this Interrogatory because it seeks information that is not
relevant an:d not reasonably calculated to lead to the discovery of admissible evidence.
Lindsey has a filed a Motion for New Trial that has not yet been heard by the Court. It is
set for hearing on February 25, 2013. If the Court grants Lindsey's Motion, the
information requested is irrelevant. In the event the Court denies the Motion, the
Defendants- Ms. Lindsey, Mr. Oliver, and Jackson Walker, LLP, will seek to supersede
the judgment by filing a Motion with the Court requesting that the Court set an
appropriate bond for the entire judgment, since the bond will involve both monetary and
non-monetary issues. See TEX. R. APP. P. 24.2. Consequently, once a supersedeas bond is
established by the Court, approved, and fmalized, the information requested will not aid
in the enforcement of the judgment if the Motion for New Trial is denied.

INTERROGATORY NO. 15:

Regarding your spouse's parents, for each parent please state-

a. the parent's full name;
b. whether he or she is now living;
c. the complete present address of the parent if living;
d. the present occupation and employer's name of the parent ifliving; and
e. the date of death and complete residential address at death if the parent is
. ,.
-..~- , deceased .

Defendant Jane 0. Lindsey's Objections and Responses
to Plaintiffs' Post-Judgment Interrogatories Page 6

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ANSWER:

Lindsey objects to this Interrogatory because it seeks information that is not
relevant and not reasonably calculated to lead to the discovery of admissible evidence.
Lindsey has a filed a Motion for New Trial that has not yet been heard by the Court. It is
set for hearing on· February 25, 2013. If the Court grants Lindsey's Motion, the
information requested is irrelevant. In the event the Court denies the Motion, the
Defendants- Ms. Lindsey, Mr. Oliver, and Jackson Walker, LLP, will seek to supersede
the judgment by filing a Motion with the Court requesting that the Court set an
appropriate bond for the entire judgment, since the bond will involve both monetary and
non-monetary issues. See TEX. R. APP. P. 24.2. Consequently, once a supersedeas bond is
established by the Court, approved, and finalized, the information requested will not aid
in the enforcement of the judgment if the Motion for New Trial is denied.

INTERROGATORY NO. 16:

Do you have one or more children now living? If you do, for each child please
state-

a. the present full name of the child;
b. whether he or she is now married;
c. the date of birth of the child; and
d. the complete present residential address of the child.
..,· ......
-~ ,~_

ANSWER:

Lindsey objects to this Interrogatory because it seeks information that is not
relevant and not reasonably calculated to lead to the discovery of admissible evidence.
Lindsey has a filed a Motion for New Trial that has not yet been heard by the Court. It is
set for hearing on February 25, 2013. If the Court grants Lindsey's Motion, the
information requested is irrelevant. In the event the Court denies the Motion, the
Defendants- Ms. Lindsey, Mr. Oliver, and Jackson Walker, LLP, will seek to supersede
the judgment by filing a Motion with the Court requesting that the Court set an
appropriate bond for the entire judgment, since the bond will involve both monetary and
non-monetary issues. See TEX. R. APP. P. 24.2. Consequently, once a supersedeas bond is
established by the Court, approved, and finalized, the information requested will not aid
in the enforcement of the judgment if the Motion for New Trial is denied.

Defendant Jane 0. Lindsey's Objections and Responses
to Plaintiffs' Post·J_udgment Interrogatories Page 7
., .

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INTERROGATORY NO. 17:

Is there presently living at your residence anyone who is not your child or spouse?
If there is, for each person please state--

a. his or her full name;
b. the person's relationship to you; and
c. the full name and complete address of the employer of the person.

ANSWER:

No.

INTERROGATORY NO. 18:

Please state the complete address (street address, city, county, state, zip code) of
each place where you have lived in the past five years and the dates you lived there.

ANSWER:

Lindsey objects to this Interrogatory because it seeks information that is not
relevant and not reasonably calculated to lead to the discovery of admissible evidence.
Lindsey has a filed a Motion for New Trial that has not yet been heard by the Court. It is
set for hearing on February 25, 2013. If the Court grants Lindsey's Motion, the
information requested is irrelevant. In the event the Court denies the Motion, the
Defendants- Ms. Lindsey, Mr. Oliver, and Jackson Walker, LLP, will seek to supersede
the judgment by filing a Motion with the Court requesting that the Court set an
appropriate bond for the entire judgment, since the bond will involve both monetary and
non-monetary issues. See TEX. R. APP. P. 24.2. Consequently, once a supersedeas bond is
established by the Court, approved, and finalized, the information requested will not aid
in the enforcement of the judgment if the Motion for New Trial is denied.

INTERROGATORY NO. 19:

Do you own one or more of your residences? If you do, for each residence you
own please state--

a. the complete address (street address, city, county, state, zip code) and full
legal description of the residence;
b. the full names and complete addresses of any other person who is a co-
owner of the property;
Defendant Jane 0. Lindsey's Objections and Responses
to Plaintiffs' Post~Judgment Interrogatories Page 8

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c. whether the residence is mortgaged;
d. the full name, complete address, and telephone number of each mortgage
holder;
e. the present balance of each mortgage;
f. the complete address to which each mortgage payment is sent;
g. the full name, complete address (street address, city, county, state, zip
code), and amount of each escrow account maintained in connection with
each mortgage; and
h. the complete address (street address, city, county, state, zip code) of the
property that you claim as a homestead.

ANSWER:

No.

INTERROGATORY NO. 20:

Do you rent one or more of the places you use as residences? If you do, for each
residence you rent please state-

a. the complete address of the residence;
b. the full name and complete address of your landlord;
c. the amount of each rental payment, the day of the month when it is due, and
the date when it is made;
d. the complete address to which rental payments are made; and
e. the amount of each deposit paid to the landlord. ·

ANSWER:

Lindsey objects to this Interrogatory because it seeks information that is not
relevant and not reasonably calculated to lead to the discovery of admissible evidence.
Lindsey has a filed a Motion for New Trial that has not yet been heard by the Court. It is
set for !fearing on February 25, 2013. If the Court grants Lindsey's Motion, the
information requested is irrelevant. In the event the Court denies the Motion, the
Defendants- Ms. Lindsey, Mr. Oliver, and Jackson Walker, LLP, will seek to supersede
the judgment by filing a Motion with the Court requesting that the Court set an
appropriate bond for the entire judgment, since the bond will involve both monetary and
non-monetary issues. See TEX. R. APP. P. 24.2. Consequently, once a supersedeas bond is
established by the Court, approved, and finalized, the information requested will not aid
in the enforcement ofthe judgment if the Motion for New Trial is denied.

Defendant Jane 0. Lindsey~s Objections and Responses
to Plaintiffs' Post.Judgment Interrogatories Page 9

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INTERROGATORY NO. 21:

Do you have one or more boarders, tenants, or subtenants? If you do, for each one
please state-

a. the person's full name;
b. the amount of rent paid by him or her;
c. the date on which the person began renting from you;
d. the rental agreement you have with him or her; and
e. the amount of any deposit made by the person to you.

ANSWER:

No.

INTERROQATORY NO. 22:

What is your usual occupation?

ANSWER:

None.

INTERROGATORY NO. 23:

Are you presently self-employed, either full time or part time? If you are, please
state-

a. the nature of your occupation, in detail;
b. how long you have been self-employed in this business;
c. the full name under which your business is operated;
d. the complete address and telephone number of your place of business;
e. your annual income for each of the last five years or for any portion of that
time that you have been self-employed;
f. your average monthly income for the last six months; and
g. whether any money is presently owed you and, if it is,from whom and in
·--what amount it is owed.

ANSWER:

No.
Defendant Jane 0. Lindsey's Objections and Responses
to Plaintiffs' Post-Judgment Interrogatories Page 10

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INTERROGATORY NO. 24:

Are you presently employed, either full time or part time, by someone other than
yourself? If you are, for each employer please state-

a. the full name, complete address, and telephone number of the e.mployer;
b. your wages or salary and how often you are paid-for example, daily,
weekly, monthly;
c. if you work for commissions, the average monthly amount of your
commissions;
d. the day of the week on which you are paid or the date or dates on which
you are paid every month or the other regular day or dates on which you are
paid; and
e. whether any compensation is presently owed you and, if so, from what
source and in what amount it is owed.

ANSWER:

No.

INTERROGATORY NO. 25:

Does your spouse work now? If so, for each job your spouse has, including self-
employment, please state-

a. whether any income is from self-employment;
b. the full name, complete address, and telephone number of each employer;
c. the annual compensation that your spouse has received for each of the last
five years or for any portion of that time during which your spouse has been
employed by another or self-employed;
d. your spouse's average monthly income for the last six months; and
e. whether any compensation ispresently owed your spouse and, if so, from
what source and in what amount it is owed.

ANSWER:

No.

'~...
Defendant Jane 0. Lindsey's Objections and Responses
to Plaintiffs• Post-Judgment Interrogatories Page ll

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INTERROGATORY NO. 26:

Are you the sole support of your family? If you are not, for each other person who
contributes support please state-

a. the full name and complete address of the contributor;
b. your relationship to the contributor;
c. the amount of each contribution and when it is normally made; and
d. the full name and complete address of each person or entity from whom the
contributor acquires the assets to make the contribution.

ANSWER:

Yes.

INTERROGATORY NO. 27:

Do you receive income or benefits from any source other than your employment
or family contributions listed above? If you do, for each source please state--

a. the full name and complete address of the source;
b. the amount of the income or benefits;
. c. precisely when each payment is received throughout the year; and
d. __
.. , t.'le
full name, complete address, and telephone number of each person,
fmancial institution, or other entity with which you deposit the payments.

ANSWER:

Social Security payments.

INTERROGATORY NO. 28:

For each of your expenses that recurs on a monthly or other regular basis and
exceeds $100, please state-

a. the frequency with which payments are made;
b. the amount of each payment and either that this amount is the same for each
payment or that this amount is an average for the past year;
c. the full name and complete address of the recipient of the payments; and
d. the full name and complete address of each person or entity from whom
you acquire the assets to make payments.
Defendant Jane 0. Lindsey's Objections and Responses
to Plaintiffs" Post·Judgment Interrogatories Page 12

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ANSWER:

Lindsey objects to this Interrogatory because it seeks information that is not
relevant and not reasonably calculated to lead to the discovery of admissible evidence.
Lindsey has a filed a Motion for New Trial that has not yet been heard by the Court. It is
set for hearing on February 25, 2013. If the Court grants Lindsey's Motion, the
information requested is irrelevant. In the event the Court denies the Motion, the
Defendants- Ms. Lindsey, Mr. Oliver, and Jackson Walker, LLP, will seek to supersede
the judgment by filing a Motion with the Court requesting that the Court set an
appropriate bond for the entire judgment, since the bond will involve both monetary and
non-monetary issues. See TEX. R. APP. P. 24.2. Consequently, once a supersedeas bond is
established by the Court, approved, and finalized, the information requested will not aid
in the enforcement of the judgment if the Motion for New Trial is denied.

INTERROGATORY NO. 29;

For each of your spouse's expenses that recurs on a monthly or other regular basis
and exceeds $100, please state--

ANSWER:
···'
•,

NIA.

INTERROGATORY NO. 30;

For each of your family's expenses that recurs on a monthly or other regular basis

Case Info

Judge

Len A. Wade Track Judge’s New Case

Case No.

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Document Filed Date

June 20, 2013

Case Filing Date

September 09, 2008

County

Parties

Marshall Searcy Attorney
Frank Greenhaw Attorney
Susanna Johnson Attorney
Bradley Berryman Attorneys for Plaintiffs
Kelly Gibbons Attorneys for Plaintiffs
Lindy Jones Attorneys for Plaintiffs
Scott Kinsel Attorneys for Plaintiffs
Michael Branyon Attorneys for Defendants
Colin Murchison Attorneys for Defendants
Brian Garrett Attorney
William Jenkins Attorneys for Defendants
J. Kirkley Attorneys for Plaintiffs
Ana Forcum Attorneys for Plaintiffs
Phillip Ledbetter Attorney
William Kirkman Attorneys for Defendants
Sean Looney Attorneys for Plaintiffs
Joseph Johnson Attorneys for Plaintiffs
Dwayne Smith Attorney
Karin Cagle Attorneys for Plaintiffs
John Gilpin Attorney
Len Wade Attorneys for Defendants
John Cayce Attorney
William Willis Attorneys for Defendants

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Document for VIRGINIA O. KINSEL, ET AL (RESTYLED PER ORDER 7/16/2020) vs ALICE LINDSEY PEACOCK, ET AL

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