Part Three: Joe D Milner and Jami Milner Crimes Proven
Continued… property including saving account money even after the settlement agreement, even after the ruling of Judge Yelenoski in favor of Guadalupe Cuellar and Raul Pavon.
Guadalupe Cuellar had to hire another attorney in Austin: Lucie Jones Guajardo who charge another $ 60000 for such removal, yet ,the savings money of Guadalupe was kept by Milner by fraud and deception.
Guadalupe and Raul Pavon alone, spent over 300000 dollars in attorneys fees, loss 20 acres of land, permanently clouded the properties title of Guadalupe Cuellar and resulting in not only Homicide, and Kidnapping but grand theft and trespassing of their home and extreme damages and mental anguish and suffering impossible to describe.
Destroyed their lifes to steal all from them.
Raul Pavon was murdered believing all his efforts , all the work of their life, their financial stability, all assets, all property, were lost.
Plaintiff Daniel Pavon an artist, had all the works of his art in his Homestead, trespassed by Milner Firm, whom took also illegal possession of over 1000 paintings, whom claim to have sold.
This Paintings were property of Raul Pavon under lien made on 2006.
On January 2011, still in proceedings for the recovery of the child, Plaintiff Daniel obtained a birth record of the child that clearly prove, the child was not of Daniel Pavon. A birth record with the finger prints of Samantha Lowry and foot prints of the child, with father unknown.
Samantha kidnapped the child soon before the DNA took place with her boyfriend Tristan Nind whom was found he arrive to Mexico City in secret on May 28, 2007 day Samantha was to arrive.
On March 2011 were discovered liens and writs of Defendants Joe Milner and Jami Milner on the homestead exempt property of Daniel Pavon. Filed against the law against Homestead exempt property, time when this cause was filed, and requested from Defendants and the court to remove such liens and writs by reason the home was to be sold.
Defendants refuse to even answer, much less remove the liens and writs, the property was required to be sold at around 30% of it value.
Clouds on Title remain in Guadalupe Properties up to date, and more concerning, such clouds accusing her and making it appear as a criminal.
The actual damages are above one million dollars, loss of irreplaceable property, and up to date, Plaintiff is unable to return to his country by the acts above, and after been deprived of all, even unable to know his legal situation in the USA. Deprived of all without due process. Without been heard, illegally restrain.
Proceedings against the crimes committed against Guadalupe and Raul continue, where Defendant Joe D Milner is a suspect of the homicide, more when through barratry as well, had people in Mexico that were paid directly from Milner Firm and added into the bills of Samantha Lowry.
Several other crimes were committed by Defendants, further described and proven in the records filed in this cause, but this should suffice to GRANT the motion for disbarments against Joe D Milner and Jami Milner Turner and proceedings to continue until Justice will be served.
Actual damages have been over one million dollars
Irreplaceable property has been sold, including cultural property illegally obtained, illegally sold.
The damages and intentional mental anguish are extreme and constant.
Physical injuries to several individual victims of Defendants, including but not limited extended family of Plaintiff whom suffered from the aggressions and violence and illegal acts of Defendants to inflict harm and as much pain and torture as possible. Even resulting in homicide.
Libel, Defamation even as to make series played in several countries claiming Plaintiff is a kidnapper.
IV
PRAYER.
Plaintiff Request to grant and order for investigation on the evidence filed to the Federal Agencies and Attorney General of Travis County Texas.
For the safety of the Public and reputation of the Justice System in Travis County Court, Plaintiff Daniel Pavon prays this court to grant the motion for disbarment of Jami Milner Turner and Joe D Milner.
Guadalupe Cuellar shall be entitled for recovery of attorney fees , extreme damages, punitive damages and a public apology.
Plaintiff Daniel is entitled to any and all relief he is justly entitled.
Over 4 years of malice of Defendants, no relief:
The acts of Defendants since the beginning but without end, are of fraud, of harassment, of greed, of lies to everyone, even Judges, even Police, even International Agencies, even Court, even Federal Agencies and all for their own gains, regardless of life, honor, Principles, Ethics, Laws, Process, Procedure, Jurisdiction, Oath or Constitution. No respect for anyone, true psychopaths without conscience, criminals feeling gods.
Who would steal ALL from an elderly couple at nearly 80 years old, in six weeks and without notice and do so, out of jurisdiction and through clear fraud with the use of extreme violence. Joe Milner and Jami Milner Turner did so.
Sincerely submitted
_________________________________________________________
Daniel Pavon Cuellar* and on behalf of others similarly situated (Victims)
Plaintiffs
Daniel Pavon Cuellar
1Registered mail only with return receipt requested
Apartado Postal 0176
Prado Norte 525,
Lomas De Chapultepec
Mexico DF 11002
*Pro se with legal advisors
1MAIL IN MEXICO IS DEPLORABLE, USE ONLY REGISTERED MAIL WITH RETURN RECEIPT REQUESTED AND ALLOW AT LEAST 1 MONTH DELIVERY TIME.
With copy to (REMOVED)
Evidence available for convenience at www.Plaintiffs.TV
All rights reserved by Daniel Pavon Cuellar December 11, 2011
CERTIFICATE OF SERVICE
The undersigned hereby certifies that pursuant to Rule 21, of TRCP, a true a and correct copy of the foregoing documents were served by regular mail to Defendants Joe D Milner and Jami Milner Turner and by email On December 13, 2011
1) Motion for disbarment against Joe Milner and Jami Milner Turner
2) PLAINTIFF SECOND AMENDMENT PETITION , MOTIONS FOR DISBARMENT AND RESPONSE TO DEFENDANTS SPECIAL EXCEPTIONS TO PLAINTIFF ORIGINAL CLAIM
3) In Lieu of Presence in Court
_________________________________________________________
Daniel Pavon Cuellar
Attorney prose
THE MILNER LAW FIRM. PLLC
3401 Glenview Avenue
Austin, Texas 78703
Criminals of Court Jami Milner Turner and Joe D Milner
Continued….
his country? Why would Defendants trespass and take possession of Plaintiff homestead for him to have no place to return to? Why would defendant obtain a false warrant against Plaintiff and keep proceedings secret? The mens reaand motive is seen clearly in the first email sent by Joe D Milner to Daniel and the results:
In fact the same evidence that shows Samantha was illegally restrained in Texas against her will in June 4, 2007provides clear evidence of the Milner firm barratry whom sends to Samantha the psychologist and even makes the appointment for her at the time she did not sought the persons employment, in fact, all she wanted was to Go to Mexico.
And the “future” witness they will use in court without ever meeting plaintiff provide his assessment, also penalized in his profession and of course, false.
With the trespassing to plaintiff homestead they began all types of illegal searches, robbery, theft of mail, destruction of the property as to make it unlivable.
COUNT FIFTEEN: KIDNAPPING BY FRAUD .
COUNT SIXTEEN: USE OF STOLEN PROPERTY (FINANCIAL BANK STATEMENT) USE FOR FRAUD IN TRAVIS COUNTY COURT TO OBTAIN GAINS FOR THEMSELVES
COUNT SEVENTEEN: FRAUD IN REAL ESTATE
Defendant Joe Milner and Jami Milner Turner continue with the illegal process and guided and direct the deadly use of force through international agencies , false claims and even press releases full of defamation based on their own criminal acts targeted against the Parents of Daniel in Mexico City.
While Plaintiff Daniel and the child were in the State of Veracruz, and this is fully known to Milner Firm who traced the emails Plaintiff Daniel sent on nearly daily basis still trying to return to his country of USA and home :Texas.
The Parents of Daniel in Mexico City receive dead threats and even their homestead in Mexico City is trespassed into and robbed. Extensive theft of valuable and documents.
Defendant Joe D Milner uses a bank statement of Bank of America stolen from the homestead of the Parents of Daniel in Mexico City, in Travis county court, of 8 months old at the time, the statement with the highest balance, and Joe D Milner uses it for fraud in court to obtain attorneys fees and a child support, still claiming the child is in Texas!
And of illegal amounts over 3000 dollars a month for child support and without the child and when the income of Plaintiff was $18000 for the whole year (2006). (And they had all tax records in the homestead of plaintiff they where trespassing into)
Defendant Joe D Milner sends his fourth amendment petition to Daniel by email, on Friday August 10, 2007claiming the final trial was on August 13, 2007 without any description or information just the fourth amendment petition and requesting the court to sale his homestead, (the home they trespasses into just weeks before) Defedant Joe Milner even requesting the Court to sale all the Fine Art paintings of Plaintiff (Inside his homestead and a collection of over 1732 Original pieces) Illegally obtain, (Robbery) illegally sold around 1100 pieces
Plaintiff Daniel sent to Joe D Milner, Jami Milner Turner and Samantha Lowry an email to be provided to the Judge.
But by seen the exhibits filed in the final Trial, Defendants Joe D Milner and Jami Milner Turner also conceal this from the Judge.
Only 18 exhibits used, including Defendants providing the homestead exemption of the home of Daniel Pavon and under his sole name, concerning, pull out on June 18, 2007 by them, the same they obtained the false warrant.
No records of income, or any evidence of their claims, the opposite, the evidence proves their fraud.
The fraud is more clear by what they obtain in the decree:
$ 4117 a month child support WITHOUT THE CHILD against a man who made $18000 gross income in 2006! And he will not be allowed to see his son unless he pays a “Ransom” of $300000 cash.
Also to mislead the court the child is in Texas.
Also around $ 200000 in attorney’s fees of course, without receipts and granting Samantha to remove the child from the USA. KIDNAPPING BY FRAUD
International kidnapping by fraud
COUNT 18: more BARRATRY Section 38.12 D)
COUNT NINETEEN : ILLEGAL LIENS AND WRITS
COUNT TWENTY: FRIVOLOUS SUIT AGAINST THE ELDERLY
More Conspiracy
FRAUD IN REAL ESTATE:
Defendant Joe D Milner through barratry, and Samantha Lowry, signs a contract with the Minton Burton Foster and Collins on July 5, 2007 ( on recovery, 40% to Attorneys) and extortion since if Samantha Lowry does not do as she is told, she will need to pay 25% more of their fictitious attorneys fees.
On July 6, 2007 Joe D Milner files his original claim (GN) against Guadalupe Cuellar and Raul Pavon, the parents of Daniel who live in Mexico and where in Mexico. Defendant Joe Milner by fraud and deception and to obtain false jurisdiction claims “all events occurred in Travis County” Immediately and on the same day, Joe Milner files illegal writs and liens against Guadalupe Cuellar and Raul Pavon properties (over 140 acres ) and against the Homestead of Plaintiff Daniel with homestead exemption, and do so with a $500 cash bond and where no legitimate debt existed.
WITHOUT NOTICE
It is until July 23, 2007 Joe D Milner aka Milner firm, works in conspiracy with Mike Techow, a process server who claims by aggravated perjury he made a service he had not made.
By August 22, 2007: Without a single piece or record of evidence of their claims obtain a judgment of 35 million dollars and another nearly $ 300000 in attorneys fees.
6 weeks total!
JOE D MILNER AND JAMI MILNER TURNER CONCEAL THE JUDGMENT AND DECREE FROM PLAINTIFF AND HIS PARENTS.
JOE D MILNER PROVIDES FAKE EMAIL ADDRESSES, FALSE LAST KNOWN ADDRESS THROUGH AGGRAVATED PERJURY TO COURT, INCOMPLETE ADDRESS WITHOUT ZIP CODE.
And immediately thereafter Defendants places in auction the properties of Guadalupe Cuellar , OVER 140 ACRES IN WEST AUSTIN.
WITHOUT NOTICE.
After Plaintiff Daniel received the documents on June 19, 2007 (FIRST COURT RECORDS) contacted the US Embassy in Mexico, the UK embassy in Mexico and the Foreign Secretariat in Mexico and remained in contact with them on usual basis.
On September 2007, still unknown what Samantha had obtained on August 13, 2007 and fully unaware of theAugust 22, 2007 judgment, Samantha and Daniel began mediation suggested by Plaintiff Daniel with the Embassies and Foreign Secretariat of Mexico to reach an agreement.
Whilst then, Guadalupe Cuellar and Raul Pavon whom were victims of even murder attempts reported to police in Mexico, they found Guadalupe Cuellar properties in auction in the internet and immediately hired Mack Ray Hernandez, an attorney in Austin Texas and another Forest Nelson from Dallas Texas.
Soon after the attorneys for Guadalupe and Raul , Mack Ray Hernandez and Forest Nelson and the attorney of Daniel hired for a settlement agreement Roy Barrera meet with Defendants Joe Milner and Jami Milner Turner also John Foster in Austin Texas for a meeting of 10 hours to hammer out a settlement agreement that was to be executed on December 3, 2007 under the The Hague Convention on the Civil Aspects of International Child Abduction
An instrument that was modified by Joe D Milner on November 26, 2007 and then Hammered out between attorneys for 10 HOURS meeting in Austin Texas on November 28, 2007.
Executed on December 3, 2007 UNDER The Hague Convention of 25 October 1980 on the Civil Aspects of International ChildAbduction is a multilateral treaty ARTICLE 7 and filed as RULE 11 AGREEMENT in Travis County Court.
COUNT TWENTY ONE: FRAUD
COUNT TWENTY THREE: BREACH OF FIDUCIARY
COUNT TWENTY FOUR: THEFT OF THE SAVINGS ACCOUNT MONEY OF GUADALUPE AND RAUL BANK OF AMERICA, THROUGH FRAUD BY JOE D MILNER
COUNT TWENTY FIVE: FORGERY OF US EMBASSY RECORDS
COUNT TWENTY SIX: INSTRUCTING TO KIDNAP A CHILD FROM MEXICO
COUNT TWENTY SEVEN: AIDING AND ABETTING KIDNAPPING
COUNT TWENTY EIGHT: RESPONSIBLE OF MURDER
Once executed the instrument and ordering the child to remain in Mexico until several clauses of the settlement agreement will be complied with, and the travel documents of the child to remain in the US Embassy to prevent the abduction and the child to remain under mutual custody of Daniel and Samantha, and a DNA to take place to establish paternity,
Samantha Lowry kidnap the child from Mexico under instructions of Joe D Milner.
Defendant Joe D Milner provided Samantha Lowry a “duress claim” using a fake email fabricated and provided by Joe D Milner (Fake email account) dated November 3, 2007. This duress was not applicable, much less in Mexico and a judge would need to first rule in actuality existed a duress, before the child could be removed from Mexico, which up to date has never happened. And the instrument remains in full force and effect.
Defendant Joe D Milner files his repudiation and duress claim in Travis County court until Samantha Lowry to kidnap the child with her boyfriend Tristan Nind and Joseph Lowry and by fraud and deception Defendant Joe D Milner complaints on the Settlement Agreement precisely on the changes Joe Milner had made on November 26, 2007.
By Testimony under oath of Samantha Lowry she claims to have signed under oath the duress claim and settlement agreement at the same time. Becoming fraud.
Defendant Joe D Milner included an exhibit in his repudiation that makes imminent the US Embassy records may have been forged, with a seal of the US embassy but without signatures.
Which may explain how Samantha was able to remove the child from Mexico when his documents where to remain in the US Embassy safeguarded by US Consul Cecil K Scott.
The settlement agreement was made between attorneys on a 10 hour meeting, Plaintiff nor his parents were present, the agreement was hammered out and agreed between attorneys and involving real estate, becoming also fraud in real estate where they induce Plaintiff and their parents to enter into such agreement knowing they will not comply.
Plaintiff relied and trusted the instrument to deliver the child and his safety and welfare , as well as Guadalupe and Raul trusted their attorneys and simply the instrument was to grant due process, Samantha and her family to move out of the Homestead of Daniel they were trespassing into and Samantha to renounce to all she obtained or won, since up to that date the judgment was unknown to Guadalupe and Raul .
The child to remain in Mexico since under the Hague Convention Treaty, the child could not be returned to Texas until the settlement agreement clauses would be complied with as, otherwise will place the child in intolerable situation to be deprived of Plaintiff, the caretaker of the child since his birth and 8 months at the time.
The Malice and Fraud of Defendants Joe D Milner permanently harm the child, and solely to continue with their fraud to obtain gains. And do so, Just before Christmas.
Guadalupe and Raul were order to go for a hearing on cause of Guadalupe Cuellar and Raul Pavon vs Samantha Lowry on January 23, 2007, time when Raul Pavon delivers evidence to their attorney Mack Ray Hernandez of the criminal acts of Defendants and the fraud.
Suddenly the hearing gets cancelled by an allege mediation of Joe D Milner.
Guadalupe and Raul Return to Mexico City, without any advancement, without any hearing. They arrive very sick from the flu and remain in Bed ( Over 70 years old)
Joe D Milner began with a request as a matter a urgency claiming Guadalupe and Raul were oblige to provide the phone records of their home in Mexico City from May 2007 to January 2008.
A request not applicable, confidential, but the conspiracy had began with Mack Ray Hernandez, good friend of Joe Milner.
On the first time Raul and Guadalupe walk out of their home precisely to obtain such records, FEBRUARY 8, 2008Raul Pavon was murdered with a 9 mm gunshot around three blocks from their home. Nothing was robbed from him.
February 26, 2008 Plaintiff receives dead threats by email if Plaintiff Daniel or his mother go to the “states” when the final trial Vs Samantha was scheduled on March 3, 2007.
Plaintiff Daniel attorney Roy Barrera, pulls out of the case after charging $15000 retainer, this attorney recommended by Mack Ray Hernandez
The final trial gets cancelled.
COUNT TWENTY NINE: INTERNATIONAL HARASSMENT
COUNT THIRTY: ATTEMPTED MURDER
COUNT THIRTY ONE: ILLEGAL SALE OF REAL ESTATE
COUNT THIRTY TWO: ILLEGAL SALE OF FINE ART, ILLEGAL POSSESSION
Immediately after the murder of Raul Pavon, Defendant Joe Milner demands a deposition of Guadalupe Cuellar be taken in Austin Texas.
The doctor of Guadalupe Cuellar provide a doctor’s note forbidding travel and stress by Guadalupe Cuellar heart condition and previous surgery and will place her life in danger.
Emphasis added: Above the age of 70 years old with previous heart surgery and less than a month from the murder of her Husband Raul Pavon whom were married for 49 years.
On March 18, 2008: Guadalupe Cuellar gives her deposition in Austin Texas, this deposition was fully inapplicable and illegal, and was in regards to three subject matters, 1) Service 2) Jurisdiction 3) the Settlement agreement
1)Service was not even attempted and in fact on November 28, 2007, Mike Techow the process server for Milner firm filed his AFFIDAVIT OF NON SERVICE. No service was attempted and service was Milner duty to prove not Guadalupe’s
2)Jurisdiction was clear, Guadalupe and Raul were in Mexico at all times during the events. Not a matter to be found in a deposition.
3)The settlement agreement was hammered out between attorneys ON AN ATTORNEY MEETING where Guadalupe was not even present, her attorneys were.
The involvement of defendants Jami Milner Turner and Joe D Milner on the homicide of Raul Pavon became more imminent when Jami Milner Turner Instructed by Joe D Milner (sitting next to her) began an interrogatory of Guadalupe Cuellar, where even if she requested a recess for not feeling well, several times, Jami Milner Turner and Joe D Milner with full intent to cause a maximum stress to a cause a heart attack, took the deposition of Guadalupe Cuellar, FOR OVER 5 HOURS . Emphasis added: Around a month after the murder of her husband.
Defendants Jami Milner Turner instructed by Joe D Milner asked all types of questions about the murder, even requesting the agencies investigating, even records, and nearly all questions of the deposition out of the scope of discovery. Mack Ray Hernandez working in conspiracy with Joe Milner.
Guadalupe Cuellar was charged $ 6000 in fees to give her deposition plus the attorneys fees and all her travel expenses.
On April 1, 2008 Jami Milner Turner and Joe D Milner instruct to sale a property of 20 acres of Raul Pavon (once deceased, property of Guadalupe) and without due process or notice to Guadalupe, even when, she was in Austin days before.
Shortly after, the final trial took place, and Judge Yelenoski ruled in favor of Guadalupe Cuellar granting a new trial,the duress claim of Joe Milner is not granted.
For information purposes: On May 2008 Plaintiff Daniel began proceedings under the Hague Convention for the return of the child.
But the fraud of Defendants Joe D Milner and Jami Milner Turner did not end, Joe Milner failed once again to remove the clouds upon title on Guadalupe Cuellar and return her continued
The criminal acts of Joe D Milner and Jami Milner Turner
Austin, Texas
January 2, 2012
The criminal acts of Joe D Milner and Jami Milner Turner from the Milner Law Firm have been proven in Travis County Court and even on TV.
The details of the criminal acts of the Milner Firm through Jami Milner Turner and Joe D Milner were not only explained, but proven with evidence records.
The Motion for disbarment against JOE D MILNER AND JAMI MILNER TURNER has been filed in Travis County Court as well as provided to the Depártment of Justice and other agencies.
The details;
RESPONSE TO DEFENDANTS SPECIAL EXCEPTIONS TO PLAINTIFF ORIGINAL CLAIM
HEREBY ATTACHED:
1) MOTION FOR DISBARMENT AGAINST DEFENDANTS JOE MILNER AND JAMI MILNER TURNER
With copy to the Department of Justice and Foreign Secretariat of Mexico.To the Honorable Judge and Travis County Court; now comes Plaintiff Daniel Pavon Cuellar individually and on behalf of others similarly situated (Victims) file the motion for disbarment of Defendants Jami Milner Turner and Joe D Milner and re-asserts his claims against Defendants in this second amendment petition and response to Defendants special exceptions.
Plaintiff Daniel Pavon Cuellar cannot be present in Court by the acts of defendants further described and proven herein, please read the attached exhibit titled” In Lieu of presence in Court” For the hearing of December 16, 2011 9AM
I.This conflict began on Memorial day of May 28, 2007. Several causes have taken place in Travis County Court, and up to date Plaintiff is prevented from Due Process or the opportunity to be heard, reason why, the evidence has been filed directly into the case file in this cause.
Nearly 400 records of evidence. Providing the liability of each of defendants.
Defendants had plenty of “Fair Notice” as to even obtain the records and evidence and claims detailed on the internet on a click.
Nevertheless, for the benefit of doubt, Plaintiff hereby sets his claims against Defendants Jami Milner Turner , Joe D Milner and the Milner Firm, more clearly and summarized.
Plaintiff does not only provide the facts, but also the evidence to prove the facts and most records of evidence been the records of Defendants filed EXPARTE, therefore, already authenticated by them.
Plaintiff Daniel Pavon Cuellar made clear he will not provide the names of the other similarly situated, because HOMICIDE AND DEAD THREATS have occurred and not even a trace of Justice seen to date. And will release the names once Justice is seen.
In fact, these claims should be investigated and prosecuted by the Attorney General and Federal agencies. Reason why at this time, copy of these records are been forwarded to the Department of Justice and other agencies.
II.Plaintiff prays the court Defendants special exceptions motion be denied. III.
PLAINTIFF ASSERTS HIS CLAIMS AGAINST DEFENDANTS JOE D MILNER, JAMI MILNER TURNER AND THE MILNER FIRM.
The Milner Firm aka Milner Law firm name is used by Defendants even on the internet and other records, without description as to what type of company, recently they added PLLC
The conflict began on Memorial Day 2007. Monday May 28, 2007 and continues to date which by the same reason Plaintiff Daniel Pavon is unable to return to his country of USA where he resided over 20 years and had his homestead and unable to be present in Court by direct acts of Defendants:
Plaintiff was deprived from all property and rights by defendants, including deprived of all Constitutional Rights, Human Rights and even in violation to several Treaties and resulting in Kidnapping, homicide and a fraud of millions of dollars.
The claims are hereby asserted and proven against Defendants Joe D Milner and Jami Milner Turner whom had plenty of Fair notice, including by publication since 2007. And evidence online of each of their fraudulent acts. Including by several previous proceedings.
INTRODUCTION At the time of the events.Plaintiff Daniel Texas resident with his HOMESTEAD at 7005 whispering creek, Austin Texas 78736
Defendant Samantha Lowry: British citizen under a tourist visa of 90 days living in 10205 Thomaswood lane, Austin Texas. FIANCEE of Plaintiff Daniel Pavon
Guadalupe Cuellar and Raul Pavon parents of Plaintiff Daniel Pavon whom lived retired in Mexico City and owned property in Austin Texas as well as their savings account.
Guadalupe Cuellar and Raul Pavon ABOVE THE AGE OF 70 YEARS OLD.
Samantha found to be pregnant in England on August 2006 and traveled under a tourist visa of 90 days to Austin Texas, on September 2006.
The child was born on March 29, 2007 and named after the “father” only with paternity to be established by DNA only.
EMPHASIS ADDED: Daniel and Samantha did not lived together, not married, ENGAGED TO BE MARRIED.
MEMORIAL DAY WEEKEND HOLLIDAY.
Daniel and Sebastian leave to Mexico City on Friday May 25, 2007 were Daniel Parents lived, and time when they will see their allege grandson for the first time, less than two months old.
Samantha Lowry to arrive on May 28, 2007 and Daniel even provided her with money for her trip.
OF COURSE, NO CUSTODY ORDERS, NO CUSTODY AGREEMENTS, NO COURT PROCEEDINGS EXISTED AT THE TIME, ENGAGED TO BE MARRIED.
But Samantha did not arrive to Mexico City, the family of Daniel trying to locate Samantha whom would not even answer her phone, contacted even her aunt in Puerto Vallarta Mexico : Carolina.
Samantha soon after delayed her trip claiming she fell ill and would arrive soon after to Mexico City.
On May 30, 2007 Daniel found of the TRESPASSING to his Homestead and immediately reported to Austin Police Department and on May 31, 2007 Daniel filed the police report with Family Violence Unit of the Austin Police Department reporting the events, the trespassing and requesting help.
On June 2, 2007 Daniel and Sebastian travel back to Austin Texas where a meeting was set with Samantha Lowry on June 3, 2007 at 6 PM in the BORDER OF Laredo where Samantha would deliver the travel documents for Daniel and Sebastian to enter the USA.
But Samantha did not arrive.
On June 6, 2007 Plaintiff continue to request the travel documents of the child from Samantha to return to Texas with the child.
On June 7, 2007 Plaintiff Daniel made several distress calls to Austin Police Department for the trespassing to his Homestead at 7005 whispering creek, (day Daniel needed to be back already in Austin for work and his car remain in a parking lot in Laredo, Texas he needed to pick up).
On June 8, 2007 Plaintiff Daniel requested from Samantha the documents of Sebastian be sent to him by fed ex to return immediately to Texas with the child and where HIS HOMESTEAD WAS.
MORE WHEN, HIS HOMESTEAD WAS TRESPASSED AND ASSESS THE DAMAGES.
But why did Samantha Lowry did not arrive on Monday May 28, 2007 to Mexico City, even if Daniel provided her $2000 for her trip and Plaintiff Family awaited her? why she did not send the travel documents of the child? Why she did not go to Laredo on June 3, 2007 for Daniel and Sebastian to enter their country? Why she did not even inform them she will not go to Laredo and not send anyone and made travel over 12 hours each way Daniel and the child to Laredo?
Evidence shows, as of June 4, 2007 Samantha Lowry whom was under an expired tourist visa in USA was unlawfully restrain through the concealment of her travel documents to prevent her to go to Mexico and the same evidence showing Samantha wanting to kill herself.
DEFENDANT JOE MILNER AND JAMI MILNER TURNER BEGAN TO “WORK” ON MAY 28, 2007 MEMORIAL DAY (OFFICIAL HOLLIDAY)
In fact, the first charges made by the Milner Law Firm billed to Samantha are dated May 28, 2007, Memorial Day (Official Holliday) The contract signed between Samantha , Her parents John Lowry and Susan Lowry with the Milner Firm on May 29, 2007.
FACTUAL EVENTS Defendant Joe D Milner and Jami Milner Turner committed the following crimes and fraudulent acts, each independently proven within the evidence filed ALREADY in court:COUNT ONE: UNLAWFUL RESTRAIN
COUNT TWO: FRAUD UPON THE COURT
COUNT THREE: FALSE CLAIMS TO FEDERAL AGENCIES, ESTATE AGENCIES , LAW ENFORCEMENT TO OBTAIN FALSE FEDERAL WARRANT AGAINST PLAINTIFF
COUNT FOUR: DISHONORABLE CONDUCT AND ILLEGAL PROCESS
COUNT FIVE : SEVERAL COUNTS OF AGGRAVATED PERJURY
COUNT SIX: ATTEMPTED MURDER/CHILD ABANDONMENT OF AMERICAN CITIZEN BABY SEBASTIAN PAVON CUELLAR AT LESS THEN TWO MONTHS OLD
Each of the above counts are proven with the “Original Petition” filed on MAY 30, 2007 by Joe D Milner in Travis County Court, when he was fully aware Daniel and the child were already in Mexico and awaiting Samantha.
On May 30, 2007: By fraud and deception and illegal process, by fraud upon the court, by perjury, through false claims and pleadings IN Travis County Court and records to be provided to Federal Agencies and Law Enforcement, for unlawful restrain of Plaintiff in Mexico:
Defendant Joe D Milner claims the child is in Austin Texas with risk of International abduction and to place restrictions against Plaintiff to obtain any travel documents for the child and if he violates the order be subject to civil and criminal penalties, also claiming the parents will be separated, when they were not married, not living together and when Joe D Milner was fully aware Plaintiff Daniel and the child were in Mexico City.
On the Same Date May 30, 2007 Defendant Joe D Milner files a Habeas Corpus, which was not applicable, but to mislead Law enforcement
On the Same date May 30, 2007 file the application of The Hague Convention of 25 October 1980 on the Civil Aspects of International Child Abduction. (TREATY) Also not applicable, but clearly appears where Samantha Lowry resided : 10205 THOMASWOOD LANE.
The attempted murder/ child abandonment of the child comes by making impossible the return of Plaintiff and the child to Texas and even the return of the child, leaving them in the foreign country of Mexico and unable to return to their country and Samantha Lowry with Daniel money.
Increased to a level of attempted Murder, by two doctors claiming the child was allergic to all types of formula and could die if not “breast” fed.
THESE PROCEEDINGS HELD SECRET FROM PLAINTIFF DANIEL PAVON
COUNT SEVEN: FALSE CLAIMS AGAINST PLAINTIFF OF FEDERAL WARRANT TO FURTHER PREVENT HIS RETURN
COUNT EIGHT: CONSPIRACY
COUNT NINE: EXTORTION
COUNT TEN: TRESPASSING TO PLAINTIFF HOMESTEAD WITH INTENT TO COMMIT AND COMMIT SEVERAL FELONIES.
COUNT ELEVEN: ILLEGAL SEARCHES AND SEIZURES AND ROBBERY
COUNT TWELVE: THEFT OF MAIL OF PLAINTIFF
COUNT THIRTEEN: BARRATRY Section 38.12 D)
COUNT FOURTEEN: GUIDING AND DIRECTING THE USE OF DEADLY FORCE
On June 8, 2007 was the first communication Plaintiff Daniel Pavon received from the Milner firm Through Jami Milner turner whom wrote an email to Daniel when she was fully aware Daniel was trying to return to Texas and needed the travel documents of the child, Jami Milner Turner claims by fraud and deception Plaintiff had a warrant for parental kidnapping , WHEN HE DID NOT.
Plaintiff Daniel immediately offered to return the child voluntarily.
On June 11, 2007 Joe D Milner writes for the first time to Daniel, with an email of extortion and threats, threatening his business partner in Austin with felony charges and threatening to enjoin the assets of his elderly parents. THIS EMAIL IS EXTREMELY IMPORTANT AS SHOWS THE CLEAR AND MALICIOUS INTENT OF MILNER, EVEN WHEN, JOE D MILNER IS NOT ONLY FULLY AWARE DANIEL HAD EVEN GO TO LAREDO ALREADY TRYING TO RETURN TO HIS COUNTRY WITH THE CHILD, BUT EVEN THAT DANIEL LEFT HIS PARENTS HOME BY THE LOWRY VIOLENCE AND THREATS AGAINST THEM AND DANIEL AND THE CHILD LEAVE TO VERACRUZ. WHERE THE TRIP WITH SAMANTHA WAS PLANNED AFTER HER ARRIVAL.
The conspiracy (two or more) is clear with Jami Milner Turner and Joe Milner
Both Jami Milner Turner and Joe Milner conceal their proceedings in Texas from Plaintiff Daniel Pavon
On June 13, 2007 Jami Milner Turner continues to claim by fraud and deception the child is in Austin Texas with risk of International abduction and to place restrictions against Plaintiff to obtain any travel documents for the child and if he violates the order will be subject to civil and criminal penalties, and to place restraining orders against Plaintiff to come near his homestead or to place false claims of trespassing , and take possession of the homestead and all contents of Plaintiff.
Jami Milner Turner was not only fully aware Daniel and the child were in Mexico City trying to return to Texas and Daniel continuing requesting the travel documents to return, Daniel had already offered to return the child, and Jami Milner was fully aware Samantha Lived in 10205 Thomaswood lane and she was trespassing in Daniel homestead through breaking a window…
It is until June 19, 2007 Defendant Jami Milner Turner and Joe D Milner provide the first documents to Daniel about the court proceedings using “alternative service” and by email, that is not only not permitted by TRCP, much less by treaties.
On June 18, 2007 the Defendants obtained the federal warrant of Parental Kidnapping against plaintiff based on their false claims, illegal process, fraud and false pleadings to court provided to federal agencies and police.
Why would Defendants Jami Milner Turner and Joe Milner make impossible the return of the child and the return of Plaintiff to their country? Why would Defendants place restrictions against Plaintiff to obtain the documents he is requesting to be able to return to CONTINUED
The Milner Law Firm Fraud and Crimes
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