5th COA

05-20-00098-CV
Demand Jury Trial
Gallagher
v
Collin County, AG and State of Texas

Brief

Introduction
TEXAS CODE
ARTICLE 1, BILL OF RIGHTS
Sec. 6. FREEDOM OF WORSHIP.
All men have a natural and indefeasible right to worship Almighty God according to the dictates of
their own consciences. No man shall be compelled to attend, erect or support any place of worship, or
to maintain any ministry against his consent. No human authority ought, in any case whatever, to
control or interfere with the rights of conscience in matters of religion, and no preference shall ever be
given by law to any religious society or mode of worship. But it shall be the duty of the Legislature to
pass such laws as may be necessary to protect equally every religious denomination in the peaceable
enjoyment of its own mode of public worship.
Sec. 19. DEPRIVATION OF LIFE, LIBERTY, PROPERTY, ETC. BY DUE COURSE OF LAW.
No citizen of this State shall be deprived of life, liberty, property, privileges or immunities, or in
any manner disfranchised, except by the due course of the law of the land.
Sec. 27. RIGHT OF ASSEMBLY; PETITION FOR REDRESS OF GRIEVANCES.
The citizens shall have the right, in a peaceable manner, to assemble together for their common good;
and apply to those invested with the powers of government for redress of grievances or other purposes,
by petition, address or remonstrance.
Sec. 29. BILL OF RIGHTS EXCEPTED FROM POWERS OF GOVERNMENT AND INVIOLATE.
To guard against transgressions of the high powers herein delegated, we declare
that everything in this "Bill of Rights" is excepted out of the general powers of government, and
shall forever remain inviolate, and all laws contrary thereto, or to the following provisions, shall
be void.

The Laws of the State of Texas do not allow the State to Sanction and or Declare someone a Vexatious
Litigant because of their Religious Beliefs, or because of their Pursuit to have Religious Rights
Recognized in the Courts. But that is what has happened here. “Because this dispute presents us with a
constitutional issue, we review the trial court's decision de novo. See, e.g., Perry v. Del Rio, 67 S.W.3d
85, 91 (Tex. 2001). Thus, we owe no deference to the trial court's decision and may proceed to resolve
the issues presented as a matter of law. Quick v. City of Austin, 7 S.W.3d 109, 116 (Tex.1998).”
-Strayhorn v. Ethical Society of Austin 110 S.W.3d 458 (Tex. App. 2003)

"It has been objected also against a bill of rights, that, by enumerating particular exceptions to
the grant of power, it would disparage those rights which were not placed in that enumeration;
and it might follow by implication, that those rights which were not singled out, were intended to
be assigned into the hands of the General Government, and were consequently insecure. This
is one of the most plausible arguments I have ever heard against the admission of a bill of rights
into this system; but, I conceive, that it may be guarded against."
-James Madison, when Introducing the Bill of Rights
The 9th Amendment
"The enumeration in the Constitution, of certain rights, shall not be construed to deny or
disparage others retained by the people."

There is a place where Human Understanding and Reality separate. Not that Reality needs to be
supplememted from that point, it is still real, Humans just don't understand it. And now adays people
are so connected and surrounded by new things, and inventions, and google, etc, it is hard to accept that
Reality is itself beyond our comprehension in many ways.

Just for examples of Human Understanding falling short. First, if you were writing a Book about
America as a Historian, you could write about Americans in the 1900s and 2000s believe in Ghosts.
Not because they read about them, but because they have experiences.

That brings us to the Human Brain, Ghosts must be Psychological, right? Well we don't understand
Brains either, because we can only Xray for Molecules that are Radio-active Isotopes which are not
representative of their Parent/Source Molecule, ex: Iodo-Melatonin is not Melatonin in the Body or
Brain, it is a new substance. And Brain scans measure responses of the Brain and Activity, not the
Driving force. We still don't understand the mind beyond the Frontal Lobe and Synapses, Memory is
only just beginning to be understood.

The Big Bang Theory, it is constantly in opposition to Jahovah with Adam and Eve, but even Big Bang
apologists have to admit that we are likely not the only Universe, and that it is not impossible that our
Universe was not just a Big Bang but the end of another Universe, populated, collapsing on itself to
produce a centerpoint from which we all are moving away from. If I say there is a force connecting you
and I, to the Earth, to the Sun, the Moon and all the Planets, it sounds New Age. But if I say "Gravity"
it's like, "Yeah, that thing that connects everything together".

"ib. §. 27. that 'los obrages los aniquilan por la inhumanidad con que se les trata.' that in other
situations also he meets death with more deliberation, and endures tortures with a firmness unknown
almost to religious enthusiasm with us"
- Thomas Jefferson, Notes on Virginia, speaking about Native Americans

Jurisdiction
Cite Austin Transcript where State gives Bob Davis the ability to represent them
Coherent Evidence of Residency
Title 5 Chpt 110 – Grievance system, no 30 days and can not be barred from filing court cases because
the Government doesn’t like your religion

Attorney General Opinion about FOIA and Discovery

“Law enforcement did not initiate this investigation, nor did law enforcement aid in this investigation.
This investigation originated and was subsequently conducted by the CCDAO and, later, by the Office
of the Attorney General (OAG) acting in conjunction with the CCDAO. The investigation lasted over
two years before Judge Wooten was initially indicted on October 14, 2010. Another nine months went
by before the final indictment against Judge Wooten was filed on July 14, 2011.” -Wooten v. Collin
County, 4:18-cv-00380-ALM (NDTX 2018)

Sanctions can’t be an outcome when you don’t appear, etc

Vexatious Litigant motion has to prove case will not be won cite case law and transcript Vexatious
Litigant case law
Collin County paying for the case to be transferred to Collin County from Austin

”42 U.S.C. § 1983, and 28 U.S.C. §§ 1331, 1343, and the Fourth and Fourteenth Amendments to the
United States Constitution, to vindicate her right to be free from wrongful arrest and prosecution, and
files this, her Original Complaint, complaining of and about John Roach, Sr., Christopher Milner,
Collin County, Texas, Gregory Abbott, and Harry White (hereinafter collectively referred to as
“Defendants”)” -Wooten v. Collin County, 4:18-cv-00380-ALM (NDTX 2018)

“1. Plaintiff, Suzanne H. Wooten, was wrongfully arrested, charged, and convicted of multiple
contrived counts of Bribery, Conspiracy to Commit Engaging in Organized Criminal Activity, Money
Laundering, and Tampering with a Governmental Record, based on false and legally untenable
allegations.
2. Defendants John Roach, Sr., Christopher Milner, Collin County, Texas, Gregory
Abbott, and Harry White conspired to wrongfully obtain an indictment and prosecute Plaintiff by
inventing and perverting law, misleading judges and juries, and taking apart Plaintiff’s life and
career one piece at a time.
3. Beyond the fact Plaintiff did not engage in the conduct alleged by Defendants,
Defendants knew full well the law did not proscribe any of the alleged conduct. In an attempt to
ensure that Plaintiff was convicted despite her innocence, and knowing she committed no
criminal act, Defendants intentionally misrepresented the law and facts and secured a wrongful
conviction of Plaintiff.
...
5. Ultimately, the criminal case against Plaintiff fell apart when her alleged co-conspirators were held
by the Texas Court of Criminal Appeals to be actually innocent and that there was no evidence of any
wrongdoing. On May 24, 2017, after spending five and a half years under community supervision,
Plaintiff was exonerated by Writ of Actual Innocence. Unfortunately, the damage had already been
done. As noted in the Order granting the Writ of Actual Innocence, Plaintiff’s civil rights have been
violated. Plaintiff now sues to recover for the harm done to her by the corrupt government agents who
targeted her unjustly.
…
The CCDAO used at least five grand juries to investigate this criminal case against Judge Wooten.
More specifically, the grand juries of the Fall of 2008, Spring of 2009, Fall of 2009, Spring of 2010,
and Fall of 2010. Four of the five grand juries were used to subpoena bank records, phone records,
credit card documents, personal records, emails, and various campaign-related vendor information.
Three of the five grand juries was used to subpoena witnesses.
…
Prior to Defendant Milner being employed at the CCDAO, grand jury investigations were initiated by
law enforcement organizations. There were no independent investigations initiated and conducted by
the CCDAO. However, when Defendant Milner started his employment with the CCDAO, the Special
Crimes Unit was formed, and grand jury cases began to be initiated from within the Special Crimes
Unit.
…
Defendant Milner explained to Judge Rusch that he wanted to leave the CCDAO with a bang. Judge
Rusch had mentioned to Judge Wooten that Defendant Milner was looking to prosecute Dallas District
Attorney Craig Watkins on a constable investigation. Further, Judge Rusch told Judge Wooten not to
worry about Judge Sandoval, but to worry about the “army” coming after her.
…
Defendant Milner told Schulte that Judge Wooten had one week to resign, or she was going to be
facing indictment and would lose her house, law license, her family, her reputation, and that he would
put her in prison for a long time. When Schulte inquired about the basis for Judge Wooten resigning,
Defendant Milner replied that “she knows what she did” and that the “Judge” (Defendant Roach
insisted that he be called Judge Roach) would look favorably upon her if she resigned.
…
On August 28, 2010, the FBI investigation into the CCDAO ended after Defendant White told FBI
investigators that the CCDAO had a legitimate investigation against Judge Wooten and that the OAG
expected to receive a grand jury indictment in the near future.
…
The constitutional injuries complained-of herein were proximately caused by a herein. pattern and
practice of misconduct which occurred with the knowledge and consent of those of Defendants who
acted in a supervisory capacity, such that these Defendants personally knew about, facilitated,
approved, and condoned this pattern and practice of misconduct, or else affirmatively turned a blind
eye thereto without taking any steps to stop it. In this way, these Defendants are personally responsible
for the complained-of injuries because they knowingly, willfully, or at least recklessly caused the
alleged deprivation of Plaintiff’s civil rights by their actions or by their deliberately indifferent failure
to act.
…
Statements the Individual Defendants made regarding Plaintiff’s alleged culpability were made with
the knowledge that said statements were false. The Individual Defendants withheld the facts of their
manipulation from Plaintiff.” -Wooten v. Collin County, 4:18-cv-00380-ALM (NDTX 2018)

Bill of Review

Cite Bill of Review Case #

I petition for a Bill of Review in the 417/16th Court. A Case in which Illegal Sanctions were granted to
the Defendant providing a Windfall in the Case, and in which all my Motions were denied, including
motions requesting transfer to Federal Court under Federal Question Jurisdiction. And now the
defendant is asking that I be held in Contempt of a court which decided a case in which it had no
jurisdiction. The court also has a conflict of interest, both in deciding a case which involved the county
that it represents and for myself because my father does business with the republican party of Collin
county and is named publicly as an affiliate of them.
See Prestige Land Iran v. Hilti, 3:15-CV-3734-L (N.D. Tex. Jun. 14, 2018)

I ask that the court set aside judgment so that we may decide the matters in the original case in a court
of appropriate jurisdiction. The defendant only filed sanctions as a strategy to scare me into dismissing
the case and then the court moved forward in a case it had no jurisdiction in sanctions that are
unfounded which is clear when you read the reason for the sanctions as they are listed as
1. filing a case against public officials which is my right
Gallagher v. Collin County, 417-01548-2017 (417th District 2017)
Gallagher v. Collin County, et al, 05-20-00098-CV (Tx. App. 2020)

2. filing a case involving the religious use of marijuana which is my right, as the criminal case that was
dismissed involves the same
State of Texas v. Gallagher, Collin County Criminal Court, 0058313010 (2010-2015)
Gallagher v. Collin County, 417-01548-2017 (417th District 2017)
Gallagher v. Collin County, et al, 05-20-00098-CV (Tx. App. 2020)

3. the sanctions request goes on to erroneously claim that the religious violations in the jail are related
to marijuana use which they are not I was denied access to my religious text which was mailed to me
by family and I was told by a preacher in the jail that I could not attend church service because I was
not Christian none of which involve the use of religious marijuana in jail and none of that is
sanctionable but sanctions were granted simply because I am homeless and indigent and could not
appear
Gallagher v. Collin County, 417-01548-2017 (417th District 2017)
Gallagher v. Collin County, et al, 05-20-00098-CV (Tx. App. 2020)

In the original case I filed against the county I outlined that the country had illegally entered our
property and had arrested me both actions in violation of my 4th amendment constitutional rights
against search and seizure and the criminal charges were later dismissed, and I have since retrieved
the police report proving that the arrest was completely illegal. Further the complaint listed a number
of religious rights violations under the 1st amendment during the time I was kept in Collin county jail
for 40 days before the case was dismissed

“"It is . . . axiomatic that the inferior federal courts are courts of limited jurisdiction. They are
'empowered to hear only those cases within the judicial power of the United States as defined by
Article III of the Constitution,' and which have been entrusted to them by a jurisdictional grant
authorized by Congress." Univ. of S. Ala. v. Am. Tobacco Co., 168 F.3d 405, 409 (11th Cir. 1999)
(quoting Taylor v. Appleton, 30 F.3d 1365, 1367 (11th Cir. 1994)). "Congress has provided for removal
of cases from state court to federal court when the plaintiff's complaint alleges a claim arising under
federal law." Rivet v. Regions Bank of Louisiana, 522 U.S. 470, 472 (1998) “Where, as here, only
state-law claims are asserted in a complaint, a claim "aris[es] under" federal law if it "necessarily
raise[s] a stated federal issue, actually disputed and substantial, which a federal forum may entertain
without disturbing any congressionally approved balance of federal and state judicial responsibilities."
Grable & Sons Metal Prods., Inc. v. Darue Eng'g & Mfg., 545 U.S. 308, 314 (2005); Gunn v.
Minton, 133 S. Ct. 1059, 1065 (2013) "The test ordinarily applied for determining whether a claim
arises under federal law is whether a federal question appears on the face of the plaintiff's well-
pleaded complaint." -Cmty. State Bank v. Strong, 651 F.3d 1241, 1251 (11th Cir. 2011), cert.
denied, 133 S. Ct. 101 (2012)” -Morgan v.PNC Bank, 14-00181-KD-B (S.D. Ala. May. 14, 2014)

“"A bill of review is an independent equitable action brought by a party to a former action seeking to
set aside a judgment, which is no longer appealable or subject to motion for new trial." Baker v.
Goldsmith, 582 S.W.2d 404, 406 (Tex.1979). According to the Texas Rules of Civil Procedure, "[o]n
expiration of the time within which the trial court has plenary power, a judgment cannot be set aside by
the trial court except by a bill of review for sufficient cause, filed within the time allowed by law."
Tex.R.Civ.P. 329b(f) (emphasis added). The rules themselves do not define "sufficient cause" but the
Texas Supreme Court, in a series of well-known cases, has set out the requirements that must be met
in order to obtain relief by bill of review. As the following review of these cases will show, the
requirements for obtaining a bill of review differ depending on the particular fact situation.”
-McDaniel v. Hale, 893 S.W.2d 652 (Tex. App. 1995)

“The trial court found that Hagedorn "had a complete and absolute defense" to the Alexanders' suit in
that he did not own the mule and was not responsible for it being on the highway when the Alexanders'
car was forced off the road; that the court would not have entered judgment for the Alexanders on
December 8, 1947, if he "had not understood from the testimony given and the statements made to
the Court at that time that defendant William Hagedorn admitted that the mule which was on the
highway and which was alleged to have caused the accident *998 * * * was his mule and was a mule
for the custody of which he was responsible"; that when Hagedorn came to the courtroom on
September 1, 1947, he came to inform the court that he did not own, and was not responsible for, the
mule at the time of the accident; and that the mule belonged to, and was under the control of,
Hagedorn's son, Robert, at the time of the accident, which fact was known to the Alexanders when
they filed suit "and at all time thereafter."” -Alexander v. Hagedorn, 226 S.W.2d 996 (Tex. 1950)

“The trial court here found that Hanks was not negligent in failing to file an answer because of his
having misplaced the citation, and that the default judgment was not caused by his negligence. It will
be here assumed that, viewing the matter under bill of review standards, there is no evidence to support
these findings, and that Hanks was negligent as a matter of law. This negligence, however, was in
failing to file an answer in time, not in his failure to timely file a motion for new trial.
Under the law, Hanks had two rights or remedies: (1) to file an answer to prevent a default judgment,
and (2) to file a motion for new trial within ten days after the judgment was taken. Rule 329b (1),
Tex.Rules Civ.Proc. Since there was a reliance on the erroneous official information given by the clerk,
it was unnecessary for Hanks to show, as was required under other circumstances in Hagedorn, that he
was prevented from filing his motion for new trial because of some accident, fraud, or wrongful act of
the opposing party.” -Hanks v. Rosser 378 S.W.2d 31 (1964)

In this Case I was unable to appear because I am Homeless and Indigent, Collin County does not
have public Transportation, and I was unable to appear. During this time Uber and Lyft did not even
exist yet, or were not something I had ever used in my life at least, as I did not begin to use them until
2018 so did not know that I could get to Collin County Court, and was indigent anyway so could not
appear. When the Court reviews the Original case they will see that not only did I request the Case be
removed to Federal Court for Federal Question Jurisdiction, but that I am Indigent and Homeless.
In this Case the County refused to Acknowledge that they have no Jurisdiction in a Case regarding
themselves, and in which I was requesting 1st Amendment and Title 42 Section 1983 Relief, this Case
was full of Federal Question Jurisdiction.

State of Texas v. Gallagher, Collin County Criminal Court, 0058313010 (2010-2015)

Gallagher v. Collin County, 417-01548-2017 (417th District 2017)
Texas Criminal Appeals Case #

“… with respect to the bribery charges at the heart of this case, this case is most unusual because the
State’s evidence is not merely insufficient - if affirmatively negates an essential element of the bribery
charges and proves appellant not guilty.” Id. at page 1, Dissenting Opinion (Tex.App. -Dallas 2014)”
-Stacy Cary v. State, 05-12- 01421-CR, 2014 WL 4261233 (Tex. App. - Dallas 2015)

Appeals reversed the convictions of David Cary and rendered acquittals on all counts, finding
that there "was insufficient evidence to support his convictions" on all counts (emphasis added).
See David Cary v. State, 460 S.W.3d 731 (Tex. App. - Dallas 2015)

In David Cary’s case, the Court of Criminal Appeals affirmed the 5th District Dallas Court of Appeals
opinion and affirmed the acquittal on all counts.
See David Cary v. State, PD-0445-15 (Tex. Crim. App. 2016)

In Stacy Cary’s case, the Court of Criminal Appeals reversed the opinion of the 5th District Dallas
Court of Appeals and rendered acquittals on all counts as well.
See Stacy Cary v. State, PD-1341-14 (Tex. Crim. App. 2016)

“As described more fully above, all of the Defendants, while acting individually, herein. jointly and in
conspiracy, as well as under color of law and within the scope of their employment, deprived Plaintiff
of her constitutional rights. Indeed, a judicial finding has been made that the arrest and prosecution of
Plaintiff violated her right to due process. Exhibit A, Order, attached hereto and incorporated herein by
reference … Defendants’ misconduct directly resulted in the unjust arrest and criminal prosecution of
Plaintiff, in violation of her rights under the United States Constitution … The misconduct described in
this Count was undertaken by employees and agents of the Collin County, including but not limited to
Defendants, pursuant to the policy and practices of Collin County to pursue wrongful arrests and
convictions through profoundly flawed investigations and false allegations. In this way, Collin County
violated Plaintiff’s rights by maintaining policies and practices that were the moving force driving the
foregoing constitutional violations. These widespread practices, so well settled as to constitute de facto
policy of Collin County, were able to exist and thrive because the policymaker(s) with authority over
the same exhibited deliberate indifference to the problem, thereby effectively ratifying it. The
widespread practices described in the preceding paragraphs were allowed to flourish because Collin
County failed to implement sufficient training and/or any legitimate mechanism for oversight or
punishment. As a result of the Defendants’ unconstitutional conduct, Plaintiff sustained, and continues
to sustain, injuries including emotional pain and suffering… Defendants John Roach, Sr., Christopher
Defendant Milner, Gregory Abbott, and herein. Defendant White (hereinafter the “Individual
Defendants”) reached an agreement amongst themselves to wrongfully arrest and prosecute Plaintiff
for false and legally untenable claims of Bribery, Conspiracy to Commit Engaging in Organized
Criminal Activity, Money Laundering, and Tampering with a Governmental Record, and to thereby
deprive Plaintiff of her constitutional rights, all as described in the various paragraphs of this
Complaint.” -Wooten v. Collin County, 4:18-cv-00380-ALM (NDTX 2018)

“That hostility surfaced at the Commission’s formal, public hearings, as shown by the record. On May
30, 2014, the seven-member Commission convened publicly to consider Phillips’ case. At several
points during its meeting, commissioners endorsed the view that religious beliefs cannot legitimately be
carried into the public sphere or commercial domain, implying that religious beliefs and persons are
less than fully welcome in Colorado’s business community. One commissioner suggested that Phillips
can believe “what he wants to believe,” but cannot act on his religious beliefs “if he decides to do
business in the state.” Tr. 23. A few moments later, the commissioner restated the same position: “[I]f a
businessman wants to do business in the state and he’s got an issue with the—the law’s impacting his
personal belief system, he needs to look at being able to compromise.” Id., at 30. Standing alone, these
statements are susceptible of different interpretations. On the one hand, they might mean simply that a
business cannot refuse to provide services based on sexual orientation, regardless of the proprietor’s
personal views. On the other hand, they might be seen as inappropriate and dismissive comments
showing lack of due consideration for Phillips’ free exercise rights and the dilemma he faced. In view
of the comments that followed, the latter seems the more likely.” -Masterpiece Cakeshop, Ltd. v.
Colorado Civil Rights Commission, 584 U.S. ___ (2018)

“Other statements by members of the city council were in a similar vein. For example, Councilman
Martinez, after noting his belief that Santeria was outlawed in Cuba, questioned: "[I]f we could not
practice this [religion] in our homeland [Cuba], why bring it to this country?" Councilman Cardoso
said that Santeria devotees at the Church "are in violation of everything this country stands for."
Councilman Mejides indicated that he was "totally against the sacrificing of animals" and
distinguished kosher slaughter because it had a "real purpose." The "Bible says we are allowed to
sacrifice an animal for consumption," he continued, "but for any other purposes, I don't believe that
the Bible allows that." The president of the city council, Councilman Echevarria, asked: "What can we
do to prevent the Church from opening?".” -Church of the Lukumi Babalu Aye, Inc. v. Hialeah, 508
U.S. 520 (1993)

Bill of Review Case Law

Writ of Error Case Law New Evidence
Clear Error cite Clear Error case law throughout

Conflict of Interest
Dad Windy Ken Paxton Collin County Republican Party Printing for city and County and articles about
the Ken Paxton connection to Collin County
Cynthia Wheless Recusal because of Human Rights complaint cite # Gallagher v. Collin County, 417-
01548-2017 (417th District 2017) and City CJC Misconduct Case # Wooten v. Collin County, 4:18-
cv-00380-ALM (NDTX 2018) Christine Nowak Federal Case # cite lines from the Nowak R&R with
Dates that it was written and ordered by the Judge later Greg Abbott then appoints Nowak’s husband
within 1 month of Nowak R&R to replace Cynthia Wheless husband, Suzanne Wooten same Judge
Andrea Thompson Wooten v. Collin County, 4:18-cv-00380-ALM (NDTX 2018) who said this case
would be an appeals case and that is why the record needed to be clear, point out Greg Abbott Wheless
connection in
“At the time of the CCDAO’s and the OAG’s investigation and prosecution of Judge Wooten, Gregory
Abbott was the Attorney General of Texas… Defendant Abbott, the OAG, allowed his office and
staff, including Defendant White, to assist the CCDAO in the investigation into Judge Wooten…
Further, Defendant White informed the FBI that CCDAO thought that once Greg Willis was elected
Collin County District Attorney, the “Wooten investigation would be discontinued if not transferred to
the AG’s office”. It will become clear that the CCDAO wanted to maintain control over the malicious
investigation and prosecution of Judge Wooten under the guise of the OAG leading the charge… D.J.
stated that the two cases against Judge Greg Willis and Judge Wooten were completely different from
all the other cases heard by the grand jury. The presentation of evidence for the two cases was strange.
The prosecutors, Davis and Defendant Milner, often set the stage for a witness by telling the grand jury
what the witnesses would testify about. The prosecutors often made comments to both D.J. individually
and to the grand jury as a whole, which led D.J. to believe both cases may have had underlying
personal issues … D.J. and other grand jury members started articulating to Davis and Defendant
Milner their concerns as to the DA’s Office having conflicts of interest with these cases. D.J. told the
prosecutors that the investigation seemed more like a political witch-hunt. D.J. asked Davis if his boss
(CCDA John Roach) knew what the prosecutors were doing. Davis responded that of course Roach
knew, that was why they were presenting the cases, and that Roach did not like this person (Judge Greg
Willis). After that comment, Davis tried to backtrack and told D.J. to forget that D.J. heard that
comment … On June 24, 2010, the Collin County grand jury (CCGJ) voted eight to three in favor of a
90-day extension to their six-month term. The CCGJ wanted to hear additional findings in the Judge
Wooten investigation. Collin County District Judge Ray Wheless was presiding over the grand jury at
that time. Judge Wheless denied the grand jury the 90-day extension because he felt the Attorney
General (OAG) prosecutor was working on behalf of the CCDAO and not the OAG.
” -Wooten v. Collin County, 4:18-cv-00380-ALM (NDTX 2018).

Ashley Wysocki in the Dallas Court In Re: Gallagher, 05-20-00128-CV (Tx. App. 2020) married to
O’Neil Wysocki Law Firm who helped to elect Andrea Thompson and in the Name change case In Re:
Gallagher, 05-20-00128-CV (Tx. App. 2020) the Representative who appeared, on no legal grounds,
stated as their Primary argument that they did not want to “Start over with the Vexatious litigant
process”, a case taken by Andrea Thompson later that month, see Gallagher v. Collin County, et al,
05-20-00098-CV (Tx. App. 2020); Gallagher v. Collin County, 417-01548-2017 (417th District
2017); Wooten v. Collin County, 4:18-cv-00380-ALM (NDTX 2018), which was added as a late
tactic when Bob Davis realized his Motion for Contempt including an indefinite jail sentence and $500
per day fee would not be upheld after Cynthia Wheless recused herself, see Gallagher v. Collin
County, 417-01548-2017 (417th District 2017) Phi Delta Phi. This is why Andrea Thompson says it is
an issue for appeal, she does not want to rock the boat because they do not want to ”Start over” see
Gallagher v. Collin County, et al, 05-20-00098-CV (Tx. App. 2020)

”A pattern of abuse of power and malicious prosecution for political gain plagues the CCDAO. In the
time surrounding the gross misuse of the law against Judge Wooten, there has accumulated multiple
examples of similar abusive conduct, including the following:
• Collin County District Judge Greg Willis was investigated by Defendant Milner and Assistant
Attorney General David Glickler while Greg Willis was a candidate for the Collin County District
Attorney position that would be vacated by Roach. Judge Greg Willis’ case was not indicted by the
grand jury convened by Defendant Milner.
• Denton County Sheriff Weldon Lucas was indicted by Defendant Milner a day after the election. The
indictment against Sheriff Lucas was thrown out by a judge just over one week later.
• Dallas County Sheriff Jim Bowles was indicted by Defendant Milner for allegedly funneling more
than $100,000 in political contributions into his personal accounts. The indictment was thrown out by
a judge. The provision of the Texas Election Code used by Defendant Milner does not even specify
criminal penalties for the alleged violations.
• Dallas County Jail Commissary Vendor Jack Madera was indicted by Defendant Milner only to have
the indictment dropped.
• J.V. 3 is a defense attorney who was indicted by Defendant Milner for tampering with a government
record. The indictment was later thrown out. Upon information and belief Defendant Milner
specifically target J.V. because of a personal vendetta.
• D.W. 4 is a defense attorney who was indicted by Defendant Milner for tampering with a government
record. The indictment was later thrown out.” -Wooten v. Collin County, 4:18-cv-00380-ALM
(NDTX 2018)

Filing Ethics Complaint notarize at Wells Fargo Financial reports and missing information

What they fail to realize is that when this is properly adjudicated (which is what they are requesting be
delayed by the court when they request that proper decisions be withheld because they do not want to
start over) is that they will have to stop. They are in violation of Rights Title 5 Chpt 110 – Grievance
system, no 30 days they do not need to start over they need to stop.

Cite transcript in Collin County where Bob Davis says he knows this is about religion

cite appearance of misconduct throughout

History
Texas Criminal Appeals Case #
State of Texas v. Gallagher, Collin County Criminal Court, 0058313010 (2010-2015)
Residence
609 Riviera

Mckinney FOIA for 2010

Kerrie Walker ineffective assistance of counsel and corruption
Fingerprint Background from In Re: Gallagher, 05-20-00128-CV (Tx. App. 2020)

“The CCDAO had ulterior malicious political motivations for prosecuting Judge Wooten. The CCDAO
wanted Judge Wooten off the bench because the CCDAO disagreed with Judge Wooten’s rulings in
criminal cases. This motivation is evident from a myriad of evidence including, a CCDAO internal
email and the redaction of incriminating statements before dissemination of that email as a response to
a public information request, the pressuring of witnesses, destruction of evidence, and the clear misuse
and abuse of the grand jury process. Additionally, it was widely known in the legal community that the
CCDAO had a Special Crimes Division headed by Defendant Milner who used heavy-handed tactics
and strategies to investigate, intimidate and often indict those who were his enemies. As detailed below,
numerous lawyers, elected officials and courthouse staffers were target by CCDAO during the two
terms former District Attorney Roach ran the CCDAO and employed Defendant Milner. The OAG
knowingly aided the CCDAO in accomplishing their goals by way of prosecuting Judge Wooten when it
was clear a crime had not occurred… As a result of this baseless investigation, prosecution, and
conviction, Judge Wooten was forced out of her position as judge of the 380 th Judicial District Court,
exactly as the CCDAO and OAG planned.” -Wooten v. Collin County, 4:18-cv-00380-ALM (NDTX
2018)

Grievance system and Attorney General Opinion about FOIA and Discovery
Wooten v. Collin County, 4:18-cv-00380-ALM (NDTX 2018) Bob Davis lying about requesting
Marijuana in jail and then disputing the existence of the felony on my record which effected my ability
to rent apartments or get jobs for 7 years and was dismissed in examining trial with me never even
being made aware of it and never being convicted or tried for it cite 2 Collin County transcripts from
Jan 23rd and Austin Transcript and EDTX R&R Nowack
Police Report # for Aggravated Perjury cite cases where people have been convicted of it
Gallagher v. Collin County, 417-01548-2017 (417th District 2017)
Cynthia Wheless Sanction calling things rumors and bad faith with no evidence of bad faith whatsoever
and Contempt motion not upheld by Andrea Thompson

“Although the trial court was acting within its discretion in proceeding to trial in the absence of
Kenneth and Clarke and in granting Lisa all of the relief sought in her counter-petition, the mere
failure of Kenneth and Clarke to appear for trial should not expose them to sanctions. A defendant
who fails to appear for trial may be subject to a judgment following trial in his absence, but the worst-
case scenario for such a defendant should be an adverse judgment for all relief sought in the plaintiff's
pleadings. See Sharpe v. Kilcoyne, 962 S.W.2d 697, 698-702 (Tex.App.-Fort Worth 1998, no pet.)
(affirming sanctions against defendant that were limited to a post-answer default judgment as to
liability and damages after defendant moved from Texas to Canada, refused to accept correspondence
from court and counsel regarding the lawsuit, and failed to appear at two deposition settings, a
sanctions hearing, and a trial setting).” -In the Interest of K.A.R. 14-03-00970-CV (Tx Crt Apps
Houston)
“Gilbert Maxwell appeals that order, complaining in four issues that the trial court abused its
discretion in assessing sanctions pursuant to its "inherent power over attorneys appearing before it"
and because the new order is not supported by the evidence. We affirm.” -Gilbertv.Tx. Mut. Insu. Co.
03-05-00787-CV (Tex. App. Dec. 19, 2008)

“...violation of a vague and uncertain court order cannot be punished by contempt.” -Ex Parte Price
741 S.W.2d 366 (1987)

Filed in 2017 and 2020 merge case Austin, Collin County, Bill of Review

Request
Bill of Review
State of Texas v. Gallagher, Collin County Criminal Court, 0058313010 (2010-2015)
Gallagher v. Collin County, 417-01548-2017 (417th District 2017)
Gallagher v. Collin County, et al, 05-20-00098-CV (Tx. App. 2020)
Title 5 Chpt 110 Relief, not “start over”, stop.
State of Texas v. Gallagher, Collin County Criminal Court, 0058313010 (2010-2015)
Gallagher v. Collin County, 417-01548-2017 (417th District 2017)
Gallagher v. Collin County, et al, 05-20-00098-CV (Tx. App. 2020)
Demand Jury Trial
Gallagher v. Collin County, 417-01548-2017 (417th District 2017)
Gallagher v. Collin County, et al, 05-20-00098-CV (Tx. App. 2020)
Records from Childhood Arrests and Probation so that any Conflicts may be revealed in these Cases as
well as Discovery for the Criminal Case in County and Redispose County Criminal Case to reflect
reality
State of Texas v. Gallagher, Collin County Criminal Court, 0058313010 (2010-2015)
Gallagher v. Collin County, 417-01548-2017 (417th District 2017)
Gallagher v. Collin County, et al, 05-20-00098-CV (Tx. App. 2020)
In Re: Gallagher, 05-20-00128-CV (Tx. App. 2020)
Rule 270 motion to merge all cases into and reopen Case from 2017 Cynthia Wheless recused
Gallagher v. Collin County, 417-01548-2017 (417th District 2017)
Gallagher v. Collin County, et al, 05-20-00098-CV (Tx. App. 2020)
Aggrevated Perjury Bob Davis
Gallagher v. Collin County, 417-01548-2017 (417th District 2017)
Gallagher v. Collin County, et al, 05-20-00098-CV (Tx. App. 2020)
Subpoena Andrew Hatch
Gallagher v. Collin County, 417-01548-2017 (417th District 2017)
Gallagher v. Collin County, et al, 05-20-00098-CV (Tx. App. 2020)

motion to retrieve copy of Police report for Agg Perjury from Collin County

S/_Ryan_Gallagher___
Rev. Ryan “Sasha” Gallagher
Mahatmajapa@gmail.com
1723 Candleglow
Castle Rock, Co 80109