On June 24, 2015 a
160309 Pls Sixth Motion to Compel Anderson-signed - MOTION - COMPEL
was filed
involving a dispute between
Doe I, John,
and
Anderson, Alexander A.,
Anderson, Levonna C.,
Anderson, William C.,
The Anderson Private School,
for OTHER PERSONAL INJURY
in the District Court of Dallas County.
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I, Individually
Plaintiffs,
v.
LEXANDER UDICIAL
NTERTAINMENT
EXAS
ONNA
John Doe I (“Plaintiff”), files this Sixth Motion to Compel LeVonna C. Anderson,
and in support thereof would show the Court as follows:
IXTH OTION TO OMPEL ONNA NDERSON
PROCEDURAL AND SUBSTANTIVE BACKGROUND
As the Court knows, this case centers on the tragic sexual assault
committed by Alexander A. Anderson on John Doe IIat Ripley’s Believe it or Not on
October 31, 2014. What the Court may not yet know, is how in the aftermath of the
assault LeVonna C. Anderson systematically and methodically made up horrible lies
about John Doe I to assassinate his char in an attempt to
undermine his credibility for the purpose of protecting her son from the criminal
justice system. These lies (referred to collectively herein as “Defamatory Statements”)
include statements that:
John Doe I was the number 1 drug dealer at Arlington Heights High
John Doe I was smoking marijuana in the parking lot at Ripley’s Believe
Sadly, LeVonna C. Anderson’s plan succeeded. However, through
discovery in this case, her lies and defamation have been, and continue to be, exposed.
To further these efforts, John Doe I requested information about the source of the
selected portion of the Grand Prairie Police Dept. case notes marked as Exhibit A-1 attached hereto
and incorporated herein by reference.
selected portion of the Grand Prairie Police Dept. case notes marked as Exhibit A-2 attached hereto
and incorporated herein by reference.
selected portion of the Texas Dept. of Family and Protective services file marked as Exhibit B
attached hereto and incorporated herein by reference.
IXTH OTION TO OMPEL ONNA NDERSON Page 2
Defamatory Statements. John Doe I further sought information about LeVonna C.
Anderson’s objective beliefs at the time she made the Defamatory Statements. In
response, LeVonna C. Anderson provided meritless objections and vague and evasive
The discovery at issue includes Requests for Admissions Nos. 5, 6, 7, 8,
Plaintiff requests that this Court overrule all of the objections at issue and
Order LeVonna C. Anderson to comply with the Texas Rules of Civil Procedure, by fully
and completely responding to the listed Requests for Admission without objection.
Plaintiff further seeks any other relief that he may be entitled, both at law and in equity.
Defendant’s Objections and Responses to Plaintiff’s Third Requests for Admission attached hereto as
Exhibit C.
IXTH OTION TO OMPEL ONNA NDERSON Page 3
JS
OHN LOAN
SLOAN MATNEY, LLP
3838 Oak Lawn Ave.
jsloan@sloanmatney.com
dlukasik@sloanmatney.com
CERTIFICATE OF CONFERENCE
Counsel for Movant and counsel for respondent have personally conducted a
conference at which there was a substantive discussion on every item presented to the
Court in this motion and despite best efforts the counsel have not been able to resolve
those matters presented.
Certified to the 9th day of March, 2016 by:
JS
__________________________________________________
IXTH OTION TO OMPEL ONNA NDERSON Page 4
CERTIFICATE OF SERVICE
I hereby certify that on the 9th day of March, 2016 a true and correct copy of the
served via e-service on:
Walters, Balido & Crain, L.L.P.
10440 North Central Expressway
Meadow Park Tower, Suite 1500
todd.parks@wbclawfirm.com
ParksEDocsNotifications@wbclawfirm.com
Rocky Feemster
Touchstone, Bernays
4040 Renaissance Tower
1201 Elm Street
Dallas, Texas 75270
rocky.feemster@tbjbs.com
Fort Worth, Texas 76126
robert@rhammerlaw.com
JS
John D. Sloan, Jr.
4812-5234-4879, v.1
IXTH OTION TO OMPEL ONNA NDERSON Page 5
EXHIBIT A-1
EXHIBIT A-2
EXHIBIT B
Document Filed Date
March 09, 2016
Case Filing Date
June 24, 2015
Category
OTHER PERSONAL INJURY
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I, Individually Plaintiffs, v. LEXANDER UDICIAL NTERTAINMENT EXAS ONNA John Doe I (“Plaintiff”), files this Sixth Motion to Compel LeVonna C. Anderson, and in support thereof would show the Court as follows: IXTH OTION TO OMPEL ONNA NDERSON PROCEDURAL AND SUBSTANTIVE BACKGROUND As the Court knows, this case centers on the tragic sexual assault committed by Alexander A. Anderson on John Doe IIat Ripley’s Believe it or Not on October 31, 2014. What the Court may not yet know, is how in the aftermath of the assault LeVonna C. Anderson systematically and methodically made up horrible lies about John Doe I to assassinate his char in an attempt to undermine his credibility for the purpose of protecting her son from the criminal justice system. These lies (referred to collectively herein as “Defamatory Statements”) include statements that: John Doe I was the number 1 drug dealer at Arlington Heights High John Doe I was smoking marijuana in the parking lot at Ripley’s Believe Sadly, LeVonna C. Anderson’s plan succeeded. However, through discovery in this case, her lies and defamation have been, and continue to be, exposed. To further these efforts, John Doe I requested information about the source of the selected portion of the Grand Prairie Police Dept. case notes marked as Exhibit A-1 attached hereto and incorporated herein by reference. selected portion of the Grand Prairie Police Dept. case notes marked as Exhibit A-2 attached hereto and incorporated herein by reference. selected portion of the Texas Dept. of Family and Protective services file marked as Exhibit B attached hereto and incorporated herein by reference. IXTH OTION TO OMPEL ONNA NDERSON Page 2 Defamatory Statements. John Doe I further sought information about LeVonna C. Anderson’s objective beliefs at the time she made the Defamatory Statements. In response, LeVonna C. Anderson provided meritless objections and vague and evasive The discovery at issue includes Requests for Admissions Nos. 5, 6, 7, 8, Plaintiff requests that this Court overrule all of the objections at issue and Order LeVonna C. Anderson to comply with the Texas Rules of Civil Procedure, by fully and completely responding to the listed Requests for Admission without objection. Plaintiff further seeks any other relief that he may be entitled, both at law and in equity. Defendant’s Objections and Responses to Plaintiff’s Third Requests for Admission attached hereto as Exhibit C. IXTH OTION TO OMPEL ONNA NDERSON Page 3 JS OHN LOAN SLOAN MATNEY, LLP 3838 Oak Lawn Ave. jsloan@sloanmatney.com dlukasik@sloanmatney.com CERTIFICATE OF CONFERENCE Counsel for Movant and counsel for respondent have personally conducted a conference at which there was a substantive discussion on every item presented to the Court in this motion and despite best efforts the counsel have not been able to resolve those matters presented. Certified to the 9th day of March, 2016 by: JS __________________________________________________ IXTH OTION TO OMPEL ONNA NDERSON Page 4 CERTIFICATE OF SERVICE I hereby certify that on the 9th day of March, 2016 a true and correct copy of the served via e-service on: Walters, Balido & Crain, L.L.P. 10440 North Central Expressway Meadow Park Tower, Suite 1500 todd.parks@wbclawfirm.com ParksEDocsNotifications@wbclawfirm.com Rocky Feemster Touchstone, Bernays 4040 Renaissance Tower 1201 Elm Street Dallas, Texas 75270 rocky.feemster@tbjbs.com Fort Worth, Texas 76126 robert@rhammerlaw.com JS John D. Sloan, Jr. 4812-5234-4879, v.1 IXTH OTION TO OMPEL ONNA NDERSON Page 5 EXHIBIT A-1 EXHIBIT A-2 EXHIBIT B