Preview
Electronically Filed
5/27/2022 6:19 PM
Hidalgo County District Clerks
Reviewed By: Krystal Hidalgo
CAUSE NO. C-2649-19-E
ELIZABETH MOLINA PEREZ, § IN THE DISTRICT COURT
Plaintiff, §
§
v. § HIDALGO COUNTY, TEXAS
§
CHRISTOPHER SANCHEZ, §
Defendant. § 275th JUDICIAL DISTRICT
MOTION TO SEAL COURT RECORDS
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES ELIZABETH MOLINA PEREZ, Plaintiff in the above styled and
numbered cause, and files this her MOTION TO SEAL RECORDS, and would
respectfully show unto the Court as follows:
Defendant’s web site, as he boldly proclaims on his letterhead, “TheRelentless
Lawyer.com”.
Defendant has demonstrated himself relentless in this matter, unfortunately
harkening back to Rambo litigation tactics common in the 1980s. He is clearly
attempting to convert this matter from a partition of real property lawsuit into mud ball
slinging contest. Every single document Defendant has filed since this Court’s
status conference has contained unprofessional and ad hominem attacks, all
completely unrelated to the merits. Indeed, some of such papers are supported by
perjurious affidavits and documents, completely unrelated to any issue in this matter.
In addition to providing Defendant some form of psychic salve, Defendant’s
Rambo tactics are designed to intimidate Plaintiff and her counsel. He is hoping that
because of such repeated attacks, he will force Plaintiff and her counsel to scurry away
or accept pesos on the dollars.
1
Electronically Filed
5/27/2022 6:19 PM
Hidalgo County District Clerks
Reviewed By: Krystal Hidalgo
To resolve the problems arising there from, Plaintiff filed a motion for sanctions,
setting forth the applicable law, and demonstrating the abusive nature of Defendant’s
filings. Plaintiff hoped that Defendant would review the authorities cited therein, and
cease his abusive conduct.
Such hope was severely misplaced. Instead, as previously mentioned,
Defendant has doubled down, increasing the number of mud balls (and increasing the
number of sanctions motions). Furthermore, Defendant has subpoenaed numerous
witnesses to testify to this Court, whose only purpose is to demean, insult humiliate,
shame, embarrass both Plaintiff and her counsel.
Obviously, such conduct possesses no place in the Hidalgo County Courthouse.
In addition to fining Defendant substantial sums, Defendant’s psychic salve and
efforts to intimidate can only be effectively remedied by sealing the record in this matter.
Accordingly, Plaintiff requests this Court to seal the record. Sealing the record is the
only method to effectively remedy Defendant’s repeated abuse. Sealing would also
further the public confidence in the judicial system.
In light of the nature of Defendant’s documents, this Court possesses the
authority to do so. Rust v. Rust, 88 S.W.2d 787. 795 (Tex. Civ. App.--Fort Worth 1935),
aff’d, 131 Tex. 532, 117 S.W.2d 59 (1938); Peck v. Murphy & Bolanz, 184 S.W. 542,
549 (Tex. Civ. App.--Dallas 1916, no writ).
WHEREFORE, PREMISES CONSIDERED, ELIZABETH MOLINA PEREZ,
Plaintiff in the above styled and numbered cause, respectfully prays that this Court seal
the record in this matter, and for all other and further relief, either at law or in equity, to
which Plaintiff shows herself justly entitled.
2
Electronically Filed
5/27/2022 6:19 PM
Hidalgo County District Clerks
Reviewed By: Krystal Hidalgo
Respectfully submitted,
LIVESAY LAW OFFICE
BRAZOS SUITES NO. 9
517 West Nolana
McAllen, Texas 78504
(956) 928-0149
Attorney@RGVAppellateLaw.com
By:__/s/_ Keith C. Livesay__________
KEITH C. LIVESAY
State Bar No. 12437100
LAW OFFICES OF JASON CASTANEDA
4014 Gulf St.
Houston, Texas 77087
Tel. (713) 808 9696
Fax. (713) 808-9898
castanedainfo@gmail.com
BY: __/S/_Jason Castaneda________
JASON CASTANEDA
Texas Bar No. 24048388
ATTORNEYS FOR PLAINTIFF,
ELIZABETH MOLINA PEREZ
CERTIFICATE OF SERVICE
I, KEITH C. LIVESAY, do hereby that I have caused to be delivered a true and
correct copy of the above and foregoing document to Defendant’s counsel of record,
Jesus Villalobos, 8701 N. 23rd Street, McAllen, Texas 78504 and Christopher Sanchez,
104 S. 23rd Street, McAllen, Texas 78501 on this the 27th day of May, 2022.
/s/__KEITH C. LIVESAY______
KEITH C. LIVESAY
3
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Keith Livesay on behalf of Keith Livesay
Bar No. 12437100
RGVAppellateLaw@yandex.com
Envelope ID: 64947596
Status as of 5/31/2022 8:26 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Christopher Sanchez 24084520 LawOfficeOfChrisSanchez@gmail.com 5/27/2022 6:19:02 PM SENT
Hitesh Chugani 24066519 HKCLaw1@gmail.com 5/27/2022 6:19:02 PM SENT
Ramon Villagomez 20581700 r.villagomez@yahoo.com 5/27/2022 6:19:02 PM SENT
JESSE VILLALOBOS JVILLALOBOSJR@YAHOO.COM 5/27/2022 6:19:02 PM SENT
JASON CASTANEDA castanedainfo@gmail.com 5/27/2022 6:19:02 PM SENT
RGV APPELLATE PARALEGAL@RGVAppellateLaw.com 5/27/2022 6:19:02 PM SENT
CHRIS SANCHEZ lawofficeofchrissanchez@gmail.com 5/27/2022 6:19:02 PM SENT
JASON CASTANEDA castanedalegal@gmail.com 5/27/2022 6:19:02 PM SENT
Associated Case Party: ChristopherRaySanchez
Name BarNumber Email TimestampSubmitted Status
Jesus Villalobos jessev@jessevillaloboslaw.com 5/27/2022 6:19:02 PM ERROR
Preview
Electronically Filed 5/27/2022 6:19 PM Hidalgo County District Clerks Reviewed By: Krystal Hidalgo CAUSE NO. C-2649-19-E ELIZABETH MOLINA PEREZ, § IN THE DISTRICT COURT Plaintiff, § § v. § HIDALGO COUNTY, TEXAS § CHRISTOPHER SANCHEZ, § Defendant. § 275th JUDICIAL DISTRICT MOTION TO SEAL COURT RECORDS TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES ELIZABETH MOLINA PEREZ, Plaintiff in the above styled and numbered cause, and files this her MOTION TO SEAL RECORDS, and would respectfully show unto the Court as follows: Defendant’s web site, as he boldly proclaims on his letterhead, “TheRelentless Lawyer.com”. Defendant has demonstrated himself relentless in this matter, unfortunately harkening back to Rambo litigation tactics common in the 1980s. He is clearly attempting to convert this matter from a partition of real property lawsuit into mud ball slinging contest. Every single document Defendant has filed since this Court’s status conference has contained unprofessional and ad hominem attacks, all completely unrelated to the merits. Indeed, some of such papers are supported by perjurious affidavits and documents, completely unrelated to any issue in this matter. In addition to providing Defendant some form of psychic salve, Defendant’s Rambo tactics are designed to intimidate Plaintiff and her counsel. He is hoping that because of such repeated attacks, he will force Plaintiff and her counsel to scurry away or accept pesos on the dollars. 1 Electronically Filed 5/27/2022 6:19 PM Hidalgo County District Clerks Reviewed By: Krystal Hidalgo To resolve the problems arising there from, Plaintiff filed a motion for sanctions, setting forth the applicable law, and demonstrating the abusive nature of Defendant’s filings. Plaintiff hoped that Defendant would review the authorities cited therein, and cease his abusive conduct. Such hope was severely misplaced. Instead, as previously mentioned, Defendant has doubled down, increasing the number of mud balls (and increasing the number of sanctions motions). Furthermore, Defendant has subpoenaed numerous witnesses to testify to this Court, whose only purpose is to demean, insult humiliate, shame, embarrass both Plaintiff and her counsel. Obviously, such conduct possesses no place in the Hidalgo County Courthouse. In addition to fining Defendant substantial sums, Defendant’s psychic salve and efforts to intimidate can only be effectively remedied by sealing the record in this matter. Accordingly, Plaintiff requests this Court to seal the record. Sealing the record is the only method to effectively remedy Defendant’s repeated abuse. Sealing would also further the public confidence in the judicial system. In light of the nature of Defendant’s documents, this Court possesses the authority to do so. Rust v. Rust, 88 S.W.2d 787. 795 (Tex. Civ. App.--Fort Worth 1935), aff’d, 131 Tex. 532, 117 S.W.2d 59 (1938); Peck v. Murphy & Bolanz, 184 S.W. 542, 549 (Tex. Civ. App.--Dallas 1916, no writ). WHEREFORE, PREMISES CONSIDERED, ELIZABETH MOLINA PEREZ, Plaintiff in the above styled and numbered cause, respectfully prays that this Court seal the record in this matter, and for all other and further relief, either at law or in equity, to which Plaintiff shows herself justly entitled. 2 Electronically Filed 5/27/2022 6:19 PM Hidalgo County District Clerks Reviewed By: Krystal Hidalgo Respectfully submitted, LIVESAY LAW OFFICE BRAZOS SUITES NO. 9 517 West Nolana McAllen, Texas 78504 (956) 928-0149 Attorney@RGVAppellateLaw.com By:__/s/_ Keith C. Livesay__________ KEITH C. LIVESAY State Bar No. 12437100 LAW OFFICES OF JASON CASTANEDA 4014 Gulf St. Houston, Texas 77087 Tel. (713) 808 9696 Fax. (713) 808-9898 castanedainfo@gmail.com BY: __/S/_Jason Castaneda________ JASON CASTANEDA Texas Bar No. 24048388 ATTORNEYS FOR PLAINTIFF, ELIZABETH MOLINA PEREZ CERTIFICATE OF SERVICE I, KEITH C. LIVESAY, do hereby that I have caused to be delivered a true and correct copy of the above and foregoing document to Defendant’s counsel of record, Jesus Villalobos, 8701 N. 23rd Street, McAllen, Texas 78504 and Christopher Sanchez, 104 S. 23rd Street, McAllen, Texas 78501 on this the 27th day of May, 2022. /s/__KEITH C. LIVESAY______ KEITH C. LIVESAY 3 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Keith Livesay on behalf of Keith Livesay Bar No. 12437100 RGVAppellateLaw@yandex.com Envelope ID: 64947596 Status as of 5/31/2022 8:26 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Christopher Sanchez 24084520 LawOfficeOfChrisSanchez@gmail.com 5/27/2022 6:19:02 PM SENT Hitesh Chugani 24066519 HKCLaw1@gmail.com 5/27/2022 6:19:02 PM SENT Ramon Villagomez 20581700 r.villagomez@yahoo.com 5/27/2022 6:19:02 PM SENT JESSE VILLALOBOS JVILLALOBOSJR@YAHOO.COM 5/27/2022 6:19:02 PM SENT JASON CASTANEDA castanedainfo@gmail.com 5/27/2022 6:19:02 PM SENT RGV APPELLATE PARALEGAL@RGVAppellateLaw.com 5/27/2022 6:19:02 PM SENT CHRIS SANCHEZ lawofficeofchrissanchez@gmail.com 5/27/2022 6:19:02 PM SENT JASON CASTANEDA castanedalegal@gmail.com 5/27/2022 6:19:02 PM SENT Associated Case Party: ChristopherRaySanchez Name BarNumber Email TimestampSubmitted Status Jesus Villalobos jessev@jessevillaloboslaw.com 5/27/2022 6:19:02 PM ERROR