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