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
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