2011
AUSTIN TEXAS
TRAVIS COUNTY COURT
Travis County Court
Austin, Texas
DANIEL PAVON CUELLAR Individually and on behalf of others similarly situated (Victims) Et Al. Plaintiff ´s
VS
Joe D Milner
Jami Milner Turner
Defendant’s
IN THE DISTRICT COURT OF
THE TRAVIS COUNTY, TEXAS
419th JUDICIAL COURT
MOTION FOR DISBARMENT
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The Honorable Court.
Now comes Plaintiff Daniel Pavon Cuellar filing this motion for disbarment against defendant Joe D Milner and Jami Milner Turner, attorneys in Travis County, Austin Texas and under Texas Government Code - Section 82.062. Disbarment
§ 82.062. DISBARMENT. Any attorney who is guilty of
barratry, any fraudulent or dishonorable conduct, or malpractice
may be suspended from practice, or the attorney's license may be
revoked, by a district court of the county in which the attorney
resides or in which the act complained of occurred. An attorney may
be suspended from practice or the attorney's license may be revoked
under this section regardless of the fact that the act complained of
may be an offense under the Penal Code and regardless of whether the
attorney is being prosecuted for or has been convicted of the
offense.
VENUE
The acts complained against Defendants, occurred in Travis County Austin Texas
GROUNDS FOR DISBARMENT
Under one or more of the acts Defendants Engaged in Travis County Court and further described on the attached exhibit titled “PLAINTIFF SECOND AMENDMENT PETITION , MOTIONS FOR DISBARMENT AND RESPONSE TO DEFENDANTS SPECIAL EXCEPTIONS TO PLAINTIFF ORIGINAL CLAIM” proven with the evidence already filed.
The acts of Defendant are beyond dishonorable conduct and malpractice, criminal conduct and clear frauds, resulting in kidnapping, Homicide and theft of real estate, fine art and even cash from Bank accounts.
Defendants acted maliciously, with ill intent, knowingly, with intent to cause dead, with intent to cause as much mental anguish and harm as they could, and did so through : Aggravated perjuries, perjuries, false pleading, fraud upon the court, extortion, harassment, illegal process, conspiracy, barratry, acts that have been the common practice of Defendants for over 4 years;
Including False testimonies to Judges, False testimonies to Federal Agencies and even International Agencies, guiding and directing the deadly use of force even internationally and targeted against the elderly whom defendants wanted to deprive from all property and assets, with the sole motive to obtain Real Estate and Millions of Dollars in Gains from an elderly couple retired in Mexico, and Defendants doing so even out of jurisdiction, violating several treaties, Human Rights, Civil Rights and Depriving of all rights, property and assets from Plaintiff and his elderly parents at nearly 80 years old, with intentional no notice. And without due process.
PRAYER
Plaintiff prays this motion be granted expeditiously.
Defendants license should be permanently suspended by one or more of the claims set herein and further matters described in the attached document titled “PLAINTIFF SECOND AMENDMENT PETITION , MOTIONS FOR DISBARMENT AND RESPONSE TO DEFENDANTS SPECIAL EXCEPTIONS TO PLAINTIFF ORIGINAL CLAIM” proven with the evidence already filed in this cause number.
Evidence proving the facts beyond any reasonable doubt and been the sealed records of the Travis County Court filed and used by Defendants Joe D Milner and Jami Milner Turner during EXPARTE proceedings in Travis County Court.
December 7, 2011
Sincerely Submitted
_______________________
Daniel Pavon Cuellar individually and on behalf of others similarly situated Plaintiffs.
Attorney prose
CAUSE NO. D-1-GN-11-001592