Answer: Denetta R. Williams v. Sonya Jones

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                                CAUSE NO. 23 DCV 304053



DENETTA R. WILLIAMS                      IN THE DISTRICT COURT OF

       Plaintiff



                                         FORT BEND COUNTY, TEXAS



SONYA JONES, et., al

       Defendants.                             JUDICIAL DISTRICT




               PLAINTIFF S RESPONSE TO CHRIS JANIECK S MOTION TO QUASH

               SUBPOENA



Plaintiff Denetta R. Williams object to and move to request for the court to
enforce the subpoena issued to Chris Janicek at her request as follows:



                                   INTRODUCTION



       Williams subpoenaed Mr. Janicek to testify as a witness for plea to the
jurisdiction   filed on behalf of several defendants who knowingly and maliciously
conspired, under the color of law to conduct an illegal school board election on
May 6, 2023, in exchange for monetary gain

       Mr. Chris Janicek   a duly elected trustee with Needville I.S.D. located in Fort

Bend County, Texas, voted along with his fellow trustees to conduct an illegal
school board election on May 6, 2023, with a complete an utter disregard for the

laws of the state. Also, Mr. Janicek voted to use taxpayers’ funds in his possession

to pay the defendant, John Oldham to conduct the illegal election.




                          ARGUMENT &AUTHORITIES



   A. Williams’ subpoena failed to attach the required witness fee.


                   The Plaintiff subpoena is enforceable and the statutory

                    requirement for the witness fee was satisfied in accordance

                   with the Rules. Williams filed an inability to pay court COSTS

                   with the Fort Bend County District Clerk in accordance with Tx

                    Rules of Civil Procedure Rule 145-Payment of Costs Not

                    Required. (a) Costs Defined. “Costs” mean any fee charged by

                   the court or an officer of the court, including but not limited

                   to, filing fees, fees for issuance and service of process, fees for

                   copies, fees for a court appointed professional, and fees

                   charged by the clerk or court reporter for the preparation of

                   the appellate record.




   B. Although Mr. Janicek is not a party to Williams’ lawsuit, he was an active

      participant in the alleged persistent election fraud committed by defendant,

      John Oldham, Fort bend County’s Election Administrator on May 6, 2023.

      With such being the case, Chris Janicek has personal knowledge that would
prove the May 6, 2023, general school board election consisted of irregular,

illegal and fraudulent activities.

                 1   January 10, 2023, under the color of law, Chris Janicek,

                     and his fellow board members, knowingly voted to order

                     an illegal school board election to be held on May 6,

                     2023.

                     Tx Education Code Chapter 11 section 11.0581 (a) JOINT

                     ELECTIONS REQUIRED. An election for trustees of an

                     independent school district shall be held on the same

                     date as: 1. The election for the members of the

                     governing body of a municipality located in the school

                     district. Considering the city of Needville did not

                     conduct an election on May 6, 2023, Needville 1.S.D.

                     was statutorily prohibited from holding an election.

                     Chris Janicek, and his fellow trustees, under the color of

                     law, voted to execute an illegal election service contract

                     provided by section 271.004 of the Election Code. (See

                     exhibit B)

                     Chris Janicek, and his fellow trustees, under the color of

                     the law, misused $13, 682.50 of taxpayers’ funds to pay

                     defendant, John Oldham, for conducting the illegal May

                     6, 2023, general school board and bond election. Tx

                     Penal Code section 39.02 (See exhibit C)

                                         Respectfully Submitted,

                                         /s/ Denetta R. Williams
CERTIFICATE OF SERVICE



       | hereby certify that on November 9, 2023, | electronically filed the
foregoing with the Clerk of the Court and a true and correct copy was served via
the court’s efile system to all participants.




                                                Respectfully Submitted,

                                                /s/ Denetta R. Williams

                                                (713) 657-9371
                                                denettawilliams@aol.com