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Case No. 22-CCV-071418
IMPERIAL LOFTS LLC IN COUNTY COURT
VS. AT LAW NO. 1 OF
SETH GUTIERREZ ET AL. FORT BEND COUNTY
NOTICE OF FILING AND ADMONISHMENT
FOR THE FILING OF 13 FRAUDULENT LAWSUITS BY
IMPERIAL LOFTS WITH AND AT THE DIRECTION OF
MADAM MARIANNA SULLIVAN
TO THE HONORABLE JUDGE OF SAID COURT:
As seen below, and as recently as August 10th 2022,
Madam Sullivan and the Lofts have been on notice of their
behavior, their crimes, and their frauds upon the Courts of
Fort Bend County, Texas.
From: EastProLaw .
Sent: Wednesday, August 10, 2022 8:43 AM
To: nguyen@hooverslovacek.com
; Holly Crampton
; Susan Norman
The Court is asked to take judicial notice of the records of the County Clerk of
Fort Bend County, Texas, showing that Imperial Lofts, and Madam Sullivan,
have previously filed 13 fraudulent eviction petitions while lacking standing
to invoke the jurisdiction of the Justice Courts.
; Brad Beers
; beale@hooverslovacek.com
; Daniel S. Edmunds
; Oubre, David
; Ogbureke, Chinasa
; ImperialLofts
Litigation ;
imperialasst@nolanred.com ;
imperialgm@nolanred.com ;
M.Sullivan@nolanred.com
Subject: VOID JUDGMENT/NOT VOIDABLE
Dear James: You are now aware that when you brought this
case on behalf of Imperial Lofts, they had no standing to sue
in a Texas Court. What is worse is that you "won" in the
County Courts, and dispossessed a citizen of his property
and did so via an Illegal proceeding in which your client
fraudulently invoked the jurisdiction of the Courts. I don't
think you would do this on purpose, but your duty here is a
clear one. To do business in Texas under an assumed name
that is not registered is:
(a) a crime, and
(b) deprives the assumed name of standing to bring a
lawsuit. See: Texas Business and Commerce Code Sec.
71.202.
A person commits an offense if the person:
(1) conducts business or renders a professional
service in this state under an assumed name; and
(2) intentionally violates this chapter.
(b) An offense under this section is a Class A
misdemeanor.
In addition, a void judgment is open to collateral attack at
any place and at any time. Finally, See Hazel-Atlas Glass Co.
v. Hartford-Empire Co., 322 U.S. 238 (1944); Universal Oil
Products Co. v. Root Refining Co., 328 U.S. 575, 580
(1946). This “historic power of equity to set aside
fraudulently begotten judgments,” Hazel-Atlas, 322 U.S., at
245, is necessary to the integrity of the courts, for
"tampering with the administration of justice in [this]
manner involves far more than an injury to a single
litigant. It is a wrong against the institutions set up to
protect and safeguard the public.” Id., at 246. This
standard applies to all courts.
Do the right thing for as I learned in Seminary--- there is a
never a good reason, to do the wrong thing.
Thanks. If you don't know what to do, ask, and I will show
you. This case is one of the dirty 13 cases that I uncovered
when Edmunds could not bring himself to apologize to a
Black man for what he and Imperial tried to do to him. This
one truly leaves Madam Sullivan exposed big time as well.
Just look at how many crimes, serious crimes Hoover
Slovacek has exposed their clients to. Don't play "musical
chairs" here, you might be the one without a "chair" when
the music stops. File a motion to vacate that judgment
under Color Tile v. Ramsey which I attach.
This E-mail, including attachments, is privileged, confidential
and covered by the Electronic Communications Privacy Act,
18 U.S.C. 2510-2521, 2701-2710. The contents of this
communication are intended for the sole use of the intended
recipient, and any disclosure, dissemination, distribution, or
duplication thereof without the express, written consent of
the sender is strictly prohibited. If you are not the intended
recipient, please immediately notify the sender by return
email, delete this communication (including any attachments
transmitted herewith) from your email box, and refrain from
disclosing the contents thereof to anyone, using it for any
purpose, or storing or copying it into any medium. Any and all
matters discussed or referenced or ???statements??? made
in this communication are covered by Texas Rule of Evidence
410 and 503, and are not admissible against the
Defendant/Plaintiff/Petitioner/Respondent/Relator/True-Party-
in-Interest/Client/ and/or witness as the case may be.
Preview
Case No. 22-CCV-071418 IMPERIAL LOFTS LLC IN COUNTY COURT VS. AT LAW NO. 1 OF SETH GUTIERREZ ET AL. FORT BEND COUNTY NOTICE OF FILING AND ADMONISHMENT FOR THE FILING OF 13 FRAUDULENT LAWSUITS BY IMPERIAL LOFTS WITH AND AT THE DIRECTION OF MADAM MARIANNA SULLIVAN TO THE HONORABLE JUDGE OF SAID COURT: As seen below, and as recently as August 10th 2022, Madam Sullivan and the Lofts have been on notice of their behavior, their crimes, and their frauds upon the Courts of Fort Bend County, Texas. From: EastProLaw . Sent: Wednesday, August 10, 2022 8:43 AM To: nguyen@hooverslovacek.com ; Holly Crampton ; Susan Norman The Court is asked to take judicial notice of the records of the County Clerk of Fort Bend County, Texas, showing that Imperial Lofts, and Madam Sullivan, have previously filed 13 fraudulent eviction petitions while lacking standing to invoke the jurisdiction of the Justice Courts. ; Brad Beers ; beale@hooverslovacek.com ; Daniel S. Edmunds ; Oubre, David ; Ogbureke, Chinasa ; ImperialLofts Litigation ; imperialasst@nolanred.com ; imperialgm@nolanred.com ; M.Sullivan@nolanred.com Subject: VOID JUDGMENT/NOT VOIDABLE Dear James: You are now aware that when you brought this case on behalf of Imperial Lofts, they had no standing to sue in a Texas Court. What is worse is that you "won" in the County Courts, and dispossessed a citizen of his property and did so via an Illegal proceeding in which your client fraudulently invoked the jurisdiction of the Courts. I don't think you would do this on purpose, but your duty here is a clear one. To do business in Texas under an assumed name that is not registered is: (a) a crime, and (b) deprives the assumed name of standing to bring a lawsuit. See: Texas Business and Commerce Code Sec. 71.202. A person commits an offense if the person: (1) conducts business or renders a professional service in this state under an assumed name; and (2) intentionally violates this chapter. (b) An offense under this section is a Class A misdemeanor. In addition, a void judgment is open to collateral attack at any place and at any time. Finally, See Hazel-Atlas Glass Co. v. Hartford-Empire Co., 322 U.S. 238 (1944); Universal Oil Products Co. v. Root Refining Co., 328 U.S. 575, 580 (1946). This “historic power of equity to set aside fraudulently begotten judgments,” Hazel-Atlas, 322 U.S., at 245, is necessary to the integrity of the courts, for "tampering with the administration of justice in [this] manner involves far more than an injury to a single litigant. It is a wrong against the institutions set up to protect and safeguard the public.” Id., at 246. This standard applies to all courts. Do the right thing for as I learned in Seminary--- there is a never a good reason, to do the wrong thing. Thanks. If you don't know what to do, ask, and I will show you. This case is one of the dirty 13 cases that I uncovered when Edmunds could not bring himself to apologize to a Black man for what he and Imperial tried to do to him. This one truly leaves Madam Sullivan exposed big time as well. Just look at how many crimes, serious crimes Hoover Slovacek has exposed their clients to. Don't play "musical chairs" here, you might be the one without a "chair" when the music stops. File a motion to vacate that judgment under Color Tile v. Ramsey which I attach. This E-mail, including attachments, is privileged, confidential and covered by the Electronic Communications Privacy Act, 18 U.S.C. 2510-2521, 2701-2710. The contents of this communication are intended for the sole use of the intended recipient, and any disclosure, dissemination, distribution, or duplication thereof without the express, written consent of the sender is strictly prohibited. If you are not the intended recipient, please immediately notify the sender by return email, delete this communication (including any attachments transmitted herewith) from your email box, and refrain from disclosing the contents thereof to anyone, using it for any purpose, or storing or copying it into any medium. Any and all matters discussed or referenced or ???statements??? made in this communication are covered by Texas Rule of Evidence 410 and 503, and are not admissible against the Defendant/Plaintiff/Petitioner/Respondent/Relator/True-Party- in-Interest/Client/ and/or witness as the case may be.