Electronically Filed

4/14/2022 7:31 AM
Laura Richard
County Clerk
Fort Bend County, Texas

NO. 22-CCV-070378

RICHARD P. JONES & § IN THE COUNTY COURT

MICHAEL JOSEPH BITGOOD §
A/K/A/ “Michael Easton” §
§
VS. § AT LAW NO. 2 OF
§
KARINA MARTINEZ, §
MARIANNA SULLIVAN, §
IMPERIAL LOFTS, LLC § FORT BEND COUNTY, TEXAS

JONES’ AND BITGOOD’S AMENDED INITIAL DISCLOSURES

TO: Defendant, Karina Martinez, by and through her counsel, David

A. Oubre, Lewis, Brisbois Bisgaard & Smith, LLP, 24 Greenway
Plaza, Suite 1400, Houston, Texas 77046

Defendant, Mariana Sullivan, by and through her counsel, David

A. Oubre, Lewis, Brisbois Bisgaard & Smith, LLP, 24 Greenway
Plaza, Suite 1400, Houston, Texas 77046

Defendant, Imperial Lofts, LLC, by and through its counsel,

David A. Oubre, Lewis, Brisbois Bisgaard & Smith, LLP, 24
Greenway Plaza, Suite 1400, Houston, Texas 77046

Plaintiffs, Richard P. Jones and Michael Joseph Bitgood, a/k/a

“Michael Easton,” provide these Required Disclosures Rule 194.2, Texas

Rules of Civil Procedure to Defendants named herein, as follows:

Jones and Bitgood’s Initial Disclosures Page 1

1. The correct names of the parties to the lawsuit.

Response: The Defendants are correctly named, as are the Plaintiffs,

including a valid and registered assumed name on file since
June of 2013.

2. The name, address, and telephone number of any potential

parties:

Response:
Hoover Slovacek, LLP
5051 Westheimer, Rd., Suite 1200
Houston, Texas 77056
713-977-8686;

Daniel Edmunds;
5051 Westheimer, Rd., Suite 1200
Houston, Texas 77056
713-977-8686;

Brice Beale,
5051 Westheimer, Rd., Suite 1200
Houston, Texas 77056
713-977-8686;

Imperial Lofts Owner LLC,

Kyle Scott, President
2020 W. 89th St., Ste 320
Leawood, Kansas 66206
913-652-8600

Jones and Bitgood’s Initial Disclosures Page 2

3. The legal theories and, in general, the factual bases of the
responding party's claims or defenses (the responding party
need not marshal all evidence that may be offered at trial):

Response:
Defendants engaged in a systematic perpetration of a fraud on the
Justice Courts, and on Appeal, to the Fort Bend County Courts at Law.
In the process of committing that fraud, they brought false, malicious
and contrived eviction petitions against Jones, and earlier against
Bitgood. Defendants, further have targeted the African-American
population to eviction after receiving payments under the CARES act.
They were further stealing from Fort Bend County, Texas, and the
United States of America. To commit the fraud, defendants enlisted
Hoover Slovacek LLP, and Daniel Edmunds and Brice Beale to commit
the following Crimes:
To do business in Texas under an assumed name that is not registered is:
(a) a crime, and
(b) deprives the assumed name of standing to bring a lawsuit.
See: Texas Business and Commerce Code Sec. 71.202.
A person commits an offense if the person:

(1) conducts business or renders a professional service in this

state under an assumed name; and

(2) intentionally violates this chapter.

(b) An offense under this section is a Class A misdemeanor.

See also: Texas Business and Commerce Code Sec. 71.201-- Civil
Action; Sanction. (a) A person’s failure to comply with this chapter
does not impair the validity of any contract or act by the person or
prevent the person from defending any action or proceeding in any court
of this state, but the person may not maintain in a court of this
state an action or proceeding arising out of a contract or act in
which an assumed name was used until an original, new, or renewed
certificate has been filed as required by this chapter.

Jones and Bitgood’s Initial Disclosures Page 3

 It is also BLACK LETTER LAW in Texas that a party that commits a
criminal act, an act of fraud, or commits a criminal offense during or
before the acts that gave rise to the litigation, cannot prevail as a matter
of public policy. See In re Prudential Ins. Co. of Am., 148 S.W.3d 124, 129
(Tex. 2004) (“As a rule, parties have the right to contract as they see fit
as long as their agreement does not violate the law or public policy”
(emphasis added)).

For the Court to fully understand the nature and the extent of the fraud
and criminal acts committed by Imperial Lofts, LLC, Lawyer Edmunds,
Hoover Slovacek, Karina Martinez, and Madam Sullivan in these cases,
the Court need only look at this record and what it reveals:

a. Prior to December 17, 2021, there was no legal entity called

“Imperial Lofts” that contracted with any of the thirteen defendants
sued by “Imperial Lofts” after February 1, 2018.

b. That on August 2, 2019, Nolan Real Estate, the parent owner

of Imperial Lofts, LLC, forfeited its Corporate Charter and legal
existence in Texas.

c. That as of November 18, 2021, the date that Karina Martinez

sued to evict Richard Jones, both she and Madam Sullivan were
still holding themselves out as employees and officers of Nolan Real
Estate Company, a defunct entity.

d. That as of July 2021, Imperial Lofts, LLC, had contracted with

Fort Bend County, Texas, to participate in the CARES Act rental
assistance program, and that as part of that agreement, the LLC
agreed not to pursue any evictions against qualifying tenants, nor
attempt to charge any fees of any kind outside of the rental
payments.

Jones and Bitgood’s Initial Disclosures Page 4

 e. That on November 18, 2022, the date that Karina Martinez
sued to evict Richard Jones in violation of that very agreement
with Fort Bend County, Jones owed no past due rent, and the
charges Martinez and the LLC were trying to extract from Jones
were “late fees”—something the LLC agreed not to do.

f. That as of July 2021, Karina Martinez, acting for the LLC,

submitted a false and fraudulent W-9 form to Fort Bend County,
Texas, knowing that the false statements would be passed onto
the I.R.S. for tax purposes in connection with the thousands of
dollars that the taxpayers of Fort Bend County would be paying
to the LLC for tenants’ rent.

g. That as November 30, 2021, Fort Bend County, Texas, HAD

PAID IN FULL Jones’ rent to the LLC, and yet, Martinez and
the LLC persisted in their fraud upon the Court by advancing
the Jones case despite being paid each and every month since
July of 2021, for tenant, Richard P. Jones.

h. That on December 17, 2021, and one day after Hoover

Slovacek made false statements to Justin Joyce, Imperial Lofts,
LLC, all the way from the State of Kansas, applied for, and was
granted the DBA assumed name of Imperial Lofts by the Texas
Secretary of State, by which they could now legally do business
in Texas as Imperial Lofts (without the LLC). This DBA thereby
conclusively shows this, and any other reviewing Court, or any
other Texas agency, that the DBA did not legally exist prior to
December 17, 2021. Further, this DBA conclusively
demonstrates that Imperial Lofts lacked standing to bring any
legal actions of any kind in a Texas Court.

Jones and Bitgood’s Initial Disclosures Page 5

 i. That on January 4, 2022, within days after Jones secured a
dismissal to their first fraudulent eviction, Lawyer Edmunds,
Hoover Slovacek, Madam Sullivan, and Martinez sent or caused
to be sent to Jones a letter:
‚ demanding possession of the premises,
‚ manufacturing a “default” of the lease, and
‚ threatening to evict Jones as well as
‚ accelerating his lease obligations.

Amazingly, this time they would have standing, but, as usual, they
omitted that Fort Bend County was paying Jones’ rent.

j. That on December 8, 2021, Hoover Slovacek, via Lawyer

Edmunds entered the most bizarre notice of appearance in the
Jones case for what they knew was a non-legal entity with no
standing to appear in a Texas Court.

k. That on December 8, 2021, Lawyer Edmunds, of Hoover

Slovacek, entered a Rule 162 non-suit to the November 18, 2021,
Martinez eviction against Jones. Again, in doing so Lawyer
Edmunds made the false statement to the Court that Jones was
just recently offered rental assistance by Fort Bend County,
Texas—when the truth was that Fort Bend had been paying
Jones’ rent since July of 2021. In addition, Lawyer Edmunds
had the “affirmative duty to inform the Court that his so-called
“client” lacked standing. It is at this point that the case
should have and could have ended.

l. That on December 13, 2021, and after taking a non-suit to

the fraudulent lawsuit brought by Martinez, Lawyer Edmunds
and Hoover Slovacek, in the name of Imperial Lofts, brought a
Chapter 10 CPRC action against both Jones and Easton in which
that non-legal entity with no standing, Imperial Lofts, sought
$3,300.00 in attorney fees, and supported such claims with the
sworn affidavit of Lawyer Edmunds replete with sophomoric

Jones and Bitgood’s Initial Disclosures Page 6

 statements, false swearing, and Edmunds’ self-aggrandizement.
Again, at no time did Lawyer Edmunds or Imperial Lofts
have standing to bring suit, much less to prolong it after
taking a non-suit. Lawyer Edmunds’ affidavit claimed that his
fees were $2,200.00 when he swore to it. However, on December
16, 2021, Lawyer Edmunds upped the ante orally to $3,300.00
after making false statements to Justin Joyce about his so-called
client, and the ability of Hoover Slovacek to even be in the case.1
It is here also, that Lawyer Edmunds sunk his client by
attaching the lease to his affidavit and pleading showing
that the contract was between Imperial Lofts, LLC, and
Jones, not “Imperial Lofts”! 2

m. That as of July of 2018, there was no “Imperial Lofts” with

standing to bring suit against Michael Joseph Bitgood; that the
suit was initiated against Bitgood by Hoover Slovacek, not the
landlord LLC; 3 that Bitgood’s declaration was on file dated July
22, 2018, calling it to the attention of the Court, and that the
parties—Bitgood and Sullivan—agreed in writing to a judgment
on the merits in Bitgood’s favor, which Justin Joyce signed—
despite lacking subject matter jurisdiction—leaving only Mr.
Beers’ Ch. 27 CPRC attorney’s fees and mandatory sanctions.

The very next day, December 17, 2021, Imperial Lofts, LLC, all the way from Kansas, contacted the
Secretary of State and took out the assumed name “Imperial Lofts” to cover up Edmunds’, Martinez’,
Madam Sullivan’s and Hoover Slovacek’s massive fraud upon the Court.
2

It is for this reason that both Jones and Bitgood hired Ms. Norman to file a Chapter 27 motion to
dismiss and to seek her attorney’s fees and additional sanctions.
3

In the Bitgood case, it was Madam Sullivan herself that committed perjury by swearing to the false
statements to manufacture jurisdictional standing. .

Jones and Bitgood’s Initial Disclosures Page 7

 PROMISSORY ESTOPPEL BY THE LLC & HOOVER SLOVACEK

The LLC, Madam Sullivan, and Hoover Slovacek entered into a

binding Rule 11 Agreement with Bitgood to his motion to dismiss with
prejudice all of their frivolous claims, but, they also “boxed” themselves
in as to Mr. Beer’s fees and the sanctions, as those are mandatory, not
discretionary. (See: In Re Diogu Law Firm, 2018 Tex. App. LEXIS
8391, 2018 WL 4997322) (Holding that the non-suits DO NOT
extinguish the Chapter 27 requirements of awarding attorney’s fees
and imposing sanctions). Thus, the LLC, Madam Sullivan, and
Hoover Slovacek are estopped by judicial and promissory
estoppel. 4

CRIMINAL OFFENSES COMMITTED AND BY WHOM

Karina Martinez: Perjury, Tex. Pen. Code §37.02, times at least four;
felony tampering with governmental records, Tex. Pen. Code §37.10,
times at least four; false statements and claims to or against the
United States, 18 U.S.C. 1001 (the W-9); wire fraud, 18 U.S.C. 1343,
(transmission of the W-9 to Fort Bend via e-mail, and using the
internet to file the false evictions); Texas Business and Commerce
Code. §71.202, and theft from Fort Bend County, in addition to fraud
committed against the peace and dignity of the State.

4
.
PROMISSORY ESTOPPEL: Overview: Within contract law, promissory estoppel refers to the
doctrine that a party may recover on the basis of a promise made when the party's reliance on that
promise was reasonable, and the party attempting to recover, detrimentally–relied on the promise.
Recognition: In Cohen v. Cowles Media Co., 501 US 663 (1991), the Supreme Court recognized
promissory estoppel as a "state law doctrine creating legal obligations never explicitly assumed by
the parties that are enforceable.” Consequences: An agreement made by promissory estoppel will
typically have the same binding effects on parties that a valid contract would. If a party breaches an
obligation created by promissory estoppel, a court can choose to assign either reliance damages or
expectation damages.

Jones and Bitgood’s Initial Disclosures Page 8

 Madam Sullivan: Perjury, Tex. Pen. Code §37.02; wire fraud, 18
U.S.C. 1343; felony tampering with governmental records, Tex. Pen.
Code §37.10, (for each eviction filed that she swore to); Texas Business
and Commerce Code § 71.202; and money laundering (for taking and
processing the illegitimate payments on behalf of the LLC).

Daniel Edmunds and Hoover Slovacek: Felony tampering with

governmental records, Tex. Pen. Code §37.10 (filings of December 8,
and 13, 2021); perjury, Tex. Pen. Code §37.02 (Edmunds’ affidavit);
mail and wire fraud, (for all of Hoover Slovacek’s bills sent to the LLC
that were sent either by mail or wire, as the billings were not for a
legally recognized service, and were generated to effect, extend, and
perpetuate the LLC’s fraud upon the Courts); 18 U.S.C. 1341, and 18
U.S.C. 1343; and, Texas Business and Commerce Code §71.202, by
representing to the Courts that Imperial Lofts was a business
authorized to transact business in Texas.

MADAM SULLIVAN, EDMUNDS, AND KARINA MARTINEZ :And

finally, after having no defense to the obvious, Madam Sullivan
recruited a Sugar Land Police officer either individually or by the
“palm” to file a frivolous, malicious and unwarranted criminal charge
against Easton based on an e-mail sent to Susan Norman and copied to
all parties that did not sit well with Madam Sullivan—as the truth
never sits well with Madam Sullivan. The e-mail contained discoverable
evidence, including Martinez’s false statements, and photos that were
all matters of public record. To do this, the City of Sugar Land had to
agree to overlook investigating Madam Sullivan, Martinez, the Lofts,
and in return the City of Sugar Land received something of value to
corrupt the process and interfere with the lawful jurisdiction of this
Court. These defendants and the City of Sugar Land enjoy a special
relationship, known as the “secret handshake”!

Jones and Bitgood’s Initial Disclosures Page 9

4. The amount and any method of calculating economic damages:

Response:

Credit Reporting;
Individual Harm in Standing with Republican Party of Texas;
Damages are left to a jury to decide, however, the “cap” has been
“busted” and although the case started out as a statutory
maximum, it has now swelled by the conduct of the defendants’
and their lawyers.

5. The name, address, and telephone number of persons having

knowledge of relevant facts, and a brief statement of each
identified person's connection with the case:

Response:

David Oubre,
Lewis Brisbois Bisgaard and Smith, LLP
24 Greenway Plaza, Suite 1400
Houston, Texas 77046
(713) 659-6767 Telephone
Counsel for Defendants, Karina Martinez, Marianna Sullivan,
and Imperial Lofts, LLC

Daniel Edmunds,
Hoover Slovacek, LLP
5051 Westheimer, Rd., Suite 1200
Houston, Texas 77056
713-977-8686
Counsel for Karina Martinez, Marianna Sullivan, and Imperial
Lofts, LLC in Cause No. 21-JEV41-11379

Brice Beale,
Hoover Slovacek, LLP
5051 Westheimer, Rd., Suite 1200
Houston, Texas 77056
713-977-8686
Counsel for Karina Martinez, Marianna Sullivan, and Imperial
Lofts, LLC in Cause No. 21-JEV41-11379, and counsel in 18-

Jones and Bitgood’s Initial Disclosures Page 10

 JEV41-110069

Karina Martinez
Marianna Sullivan
Imperial Lofts, LLC
c/o David Oubre and Chinasa Ogbureke
Lewis Brisbois Bisgaard & Smith LLP
24 Greenway Plaza, #1400
Houston, Texas 77046
Tel: (713) 659-6767
Defendants

Michael Joseph Bitgood

a/k/a Michael Easton
503 FM 359, Suite 130- 116
Richmond, Texas 77406
Tel: (281) 415-8655
Plaintiff

Richard P. Jones
c/o Susan C. Norman
Law Office of Susan C. Norman
P.O. Box 55585
Houston, Texas 77255
Tel: (713) 882-2066
Plaintiff

Meredith Riede
2700 Town Center Blvd., N.
Sugar Land, Texas 77479
(281-275-2750
City Attorney for Sugar Land, Texas

Jones and Bitgood’s Initial Disclosures Page 11

 Officer FNU Spencer/Spenser
2 Stadium Drive,
Sugar Land, Texas 77498
281-733-2780
Original officer used by Madam Sullivan for purposes of official
oppression

6. A copy-or a description by category and location-of all

documents, electronically stored information, and tangible
things that the responding party has in its possession, custody,
or control, and may use to support its claims or defenses, unless
the use would be solely for impeachment:

Response: The records in Cause Numbers 18-JEV41-10069, in Justice Court

No. 4 of Fort Bend County, Texas; Cause No. 21-JEV41-11379, In
Justice Court No. 4, of Fort Bend County, Texas; Cause No.
22-CCV-070615 in the County Court at Law No. 4, of Fort Bend
County, Texas; Cause No.18-CCV-062420, in the County Court at
Law No. 5, of Fort Bend County, Texas. All the documents are
available on line. In addition, all writings and documents
produced and tendered to and sent to Madam Sullivan and
Hoover Slovacek from 2018 to the present date from witnesses
and the Plaintiffs in this case. Plaintiffs are awaiting the release
of the offense report from the City of Sugar Land. In addition,
plaintiffs’ also direct the defendants to the Reporter’s
Record made on April 13th 2022 in cause No. 22-CCV-070615
wherein witness Brice Beale lied to the Court repeatedly,
and did not rebut the systemic racism charge leveled at
Imperial Lofts.

7. Any indemnity and insuring agreements described in Rule

192.3(f):

Response: None

Jones and Bitgood’s Initial Disclosures Page 12

8. Any settlement agreements described in Rule 192.3(g):

Response: None at this time

9. Any witness statements described in Rule 192.3(h):

Response: Amanda Love. Tendered to Madam Sullivan and Hoover-Slovacek

along with the “unauthorized” photos of Madam Sullivan
attempting to recruit Ms. Love.

10. In a suit alleging physical or mental injury and damages from

the occurrence that is the subject of the case, all medical
records and bills that are reasonably related to the injuries or
damages asserted or, in lieu thereof, an authorization
permitting the disclosure of such medical records and bills:

Response: None at this time

11. In a suit alleging physical or mental injury and damages from

the occurrence that is the subject of the case, all medical
records and bills obtained by the responding party by virtue of
an authorization furnished by the requesting party.

Response: None at this time.

12. The name, address, and telephone number of any person who
may be designated as a responsible third party:

Response: NONE, the DEFENDANTS SHOULD “PROUDLY” OWN

THIS ONE.

Jones and Bitgood’s Initial Disclosures Page 13

 Respectfully submitted,

/s/Michael Joseph Bitgood /s/ Susan C. Norman

a/k/a/ Michael Easton Susan C. Norman,
503 FM 359, Suite 130-220 SBOT 15083020
Richmond, Texas 77406 P. O. Box 55585
d/b/a/ “Michael Easton” Houston, Texas 77255
281-415-8655 713-882-2066
EastProLaw@msn.com 281-402-3682 Fax
SueNorman@SueNormanLaw.com
Counsel for Richard P. Jones

CERTIFICATE OF SERVICE

On April 14th, 2022, I certify that I served a true and correct copy of
this instrument via the Texas e-filing system to all interested parties
pursuant to T.R.C.P. 21 and 21a via email and/or by e-filing:

/s/ Susan C. Norman

Susan C. Norman

Jones and Bitgood’s Initial Disclosures Page 14

 Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.

Michael Easton on behalf of Susan Norman

Bar No. 15083020
EastProLaw@outlook.com
Envelope ID: 63564725
Status as of 4/14/2022 8:50 AM CST

Associated Case Party: MichaelJosephBitgood

Name BarNumber Email TimestampSubmitted Status

Michael Easton EastProLaw@msn.com 4/14/2022 7:31:08 AM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Kathy Truong Kathy.Truong@lewisbrisbois.com 4/14/2022 7:31:08 AM SENT

David Oubre David.Oubre@lewisbrisbois.com 4/14/2022 7:31:08 AM SENT

Chinasa Ogbureke Chinasa.Ogbureke@lewisbrisbois.com 4/14/2022 7:31:08 AM SENT

Tiffany Farr tiffany.farr@lewisbrisbois.com 4/14/2022 7:31:08 AM SENT

Associated Case Party: Marianna Sullivan

Name BarNumber Email TimestampSubmitted Status

Marianna Sullivan imperialgm@nolanRed.com 4/14/2022 7:31:08 AM SENT

Marianna Sullivan M.Sullivan@NolanRed.com 4/14/2022 7:31:08 AM SENT

Associated Case Party: Imperial Lofts LLC

Name BarNumber Email TimestampSubmitted Status

Karina Martinez ImperialAsst@nolanred.com 4/14/2022 7:31:08 AM SENT

Brice Beale Beale@HooverSlovacek.com 4/14/2022 7:31:08 AM SENT

Marianna Sullivan imperialgm@nolanRed.com 4/14/2022 7:31:08 AM SENT

Melissa Singer M.Singer@NolanRed.com 4/14/2022 7:31:08 AM ERROR

Daniel SwiftEdmunds EDmunds@HooverSlovacek.com 4/14/2022 7:31:08 AM SENT

Associated Case Party: RichardPJones

 Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.

Michael Easton on behalf of Susan Norman

Bar No. 15083020
EastProLaw@outlook.com
Envelope ID: 63564725
Status as of 4/14/2022 8:50 AM CST

Associated Case Party: RichardPJones

Name BarNumber Email TimestampSubmitted Status

Susan CNorman SueNorman@SueNormanLaw.com 4/14/2022 7:31:08 AM SENT

Associated Case Party: Karina Martinez

Name BarNumber Email TimestampSubmitted Status

Marianna Sullivan imperialgm@nolanRed.com 4/14/2022 7:31:08 AM SENT

Associated Case Party: Michael Easton

Name BarNumber Email TimestampSubmitted Status

Brad BBeers BBeers@BeersLaw.net 4/14/2022 7:31:08 AM SENT

Brad BBeers BBeers@BeersLaw.net 4/14/2022 7:31:08 AM SENT

Ronald WRobinson Reocom.net@gmail.com 4/14/2022 7:31:08 AM SENT

Richard PJones DickeyJones365@gmail.com 4/14/2022 7:31:08 AM SENT