The Court is Disqualified and There’s a Hearing That’s Scheduled for Monday

Plaintiff now formalizes his request to stay the scheduled sanctions hearing set for Monday, 20 March, 2023 at 2 pm in this court, per Plaintiff’s Motion to Disqualify Judge Lauren Reeder, Image No. 107121410 and Verified Declaration and Plaintiff’s Verified Declaration in Support of Motion to Disqualify Judge Lauren Reeder, Image No. 107121411 docketed online today, Friday, March 17, 2023.

ARGUMENT AND AUTHORITIES

The Plaintiff’s disqualification motion has instant impact, and Judge Lauren Reeder cannot respond to it.

See; “If a motion is filed before evidence has been offered at trial, the respondent judge must take no further action in the case until the motion has been decided, except for good cause stated in writing or on the record.

TEX.R.CIV.P. 18a(f).” Sims v. Sims, 623 S.W.3d 47, 61 (Tex. App. 2021).

A replacement judge may be assigned, however, the judge is subject to a cooling off period wherein Plaintiff can accept or reject the replacement judge. See; Mitchell Energy Corp. v. Ashworth, 943 S.W.2d 436 (Tex. 1997), discussing mandatory disqualification of assigned judges in Texas.

With the hearing set for Monday at 2 p.m., it would be unrealistic for all this to be achieved and decided upon, considering the time available today and the fact that Plaintiff has to contact the subpoena’d witnesses and/or their counsel or agents to let them know the current position. To have the witnesses on call today and Monday would be extremely unfair and the short notice is due to the court’s own malfeasance in the Orders which were not timely released onto the docket.

Anticipating objections, the 10-day notice prior to this sanctions hearing does not apply, due to the unconstitutional and prejudicial acts of Judge Lauren Reeder, as detailed in the Plaintiff’s disqualification motion and verified declaration in support.

Let it be known, the Court cannot alter its website.   The entire structure of our society relies upon fair, reliable and accurate filing and recording of pleadings and motions, and their dates from which rights, remedies and obligations run.   These issues could give rise to action under 42 USCA § 1983 or other remedies, constitute a violation of Texas Penal Code Section 37.10 V.T.C.A., Government Code § 51.304, 51.901, or other applicable statutes, as well as regulatory matters affecting the Court.  This creates an interest in the litigation and constitutes a deprivation of due process as a matter of law.  This dispute requires a new forum free from the appearances of impropriety and conflicted interests now associated with this Court from this course of events.

CONCLUSION

Plaintiff prays the Court GRANT the Motion to Stay, timely notices and cancels the scheduled hearing set for Monday, March 20, 2023 at 2 pm and for such other and further relief at law or in equity to which Plaintiff may be justly entitled.

RESPECTFULLY submitted this 17th day of March, 2023.

I declare under penalty of perjury that the foregoing is true and correct. This declaration under Chapter 132, Civil Practice and Remedies Code.