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Old February 5th 10, 08:32 PM posted to rec.games.chess.politics
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Default Rule 11 against William G. Putnicki


UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
EL PASO DIVISION


MARCUS WAYNE ROBERTS, a citizen
of the United States of America and an Ambassador
(or former Ambassador) of the Federation of Saint Christopher
and Nevis, appearing as a REGENT of Queen Elizabeth II,
Queen of Great Britain, Northern Ireland, and St Kitts and Nevis
Plaintiff.


V. Civil Action No. 3:09-cv-00403-PRM

RIO GRANDE ELECTRIC COOPERATIVE, Inc., A Texas Corporation,

DAN LAWS, CEO/General Manager of Rio Grande Electric Cooperative,
Inc.,

DARLENE LAWS, wife of Dan Laws,

GREGG GARDNER, Area Manager of Rio Grande Electric Cooperative, Inc.,

CERRO ALTO DEVELOPMENT Inc., A Texas Corporation,

JOHN E. TURNER, President, Cerro Alto Development, Inc. and Constable
of Hudspeth County, Texas District 3,

JUSTICE OF THE PEACE COLLIER, District 3, Hudspeth County, Texas

KIT BRAMBLETT, County Attorney for Hudspeth County, Texas

WILLIAM G. PUTNICKI, Clerk of Court for the Western District of Texas


MOTION FOR LEAVE OF COURT TO FILE FIRST AMENDED COMPLAINT WHERE NO
LEVE OF COURT IS NECCASSARY, CLERK REJECTS FILING IN LETTER OF FEBUARY
3, 2010
The Plaintiff again charges corruption in the Western District of
Texas against the Clerk of the Court. Mr. Puntnicki has refused to
file my FIRST AMENDED COMPLAINT. No answer or responsive pleading has
been filed. The Plaintiff has an ABSOULTE RIGHT to file an amended
complaint, because DEFENDANTS HAVE not answered his complaint! None
the less, the Plaintiff moves for LEAVE OF THE COURT to file his FIRST
AMENDED COMPLAINT, and requests 10,000 dollars in punitive damages for
MENTAL ANGUISH against the Clerk of Court for refusing to file his
first amended complaint. EVEN if Plaintiff is incorrect in his
interpretation, FIRST AMENDED COMPLAINT should have been filed an
stricken.
Plaintiff asks for Rule 11 CONTEMPT HEARING against Clerk of Court.







Rule 15. Amended and Supplemental Pleadings
(a) AMENDMENTS BEFORE TRIAL.
(1) Amending as a Matter of Course. A party may amend its
pleading once as a matter of course:
(A) before being served with a responsive pleading; or
(B) within 20 days after serving the pleading if a responsive
pleading is not allowed and the action is not yet on
the trial calendar.
21 FEDERAL RULES OF CIVIL PROCEDURE Rule 15
(2) Other Amendments. In all other cases, a party may amend
its pleading only with the opposing partyís written consent or
the courtís leave. The court should freely give leave when justice so
requires.


























CERTIFICATE OF SERVICE

I hereby certify that on the 5th day of February, 2010, I served by
US mail to the last known addresses pursuant to Fed. R. Civ. 5(b)(2)
(C) copies of the first amended complaint to all attorneys of record
and to the Clerk of the Court of the Western District of Texas.
Douglas D. Fletcher
8750 North Central Expressway
Suite 1600
Dallas, Texas 75231

H. Keith Myers
PO BOX 1977
El Paso, Texas 79950-1977

Colbert N. Coldwell
4171 N Mesa, Suite B-201
El Paso, Texas 79902

Lea Ann Ream
7550 IH-10 West
Suite 800
San Antonio, TX 78229-5815

Bryan Harris Hall
5915 Silver Springs Dr. Bldg 4
El Paso, TX 79912


Marcus Roberts
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Old February 5th 10, 10:42 PM posted to rec.games.chess.politics
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First recorded activity by ChessBanter: Aug 2009
Posts: 122
Default Rule 11 against William G. Putnicki

snip

Plaintiff asks for Rule 11 CONTEMPT HEARING against Clerk of Court.


A motion for Sanctions pursuant to Rule 11 of the FRCP is not the same thing
as Contempt of Court, Marcus. I suggest that actually reading the Federal
Rules of Civil Proceedure might be in order here. Courts to not look kindly
upon thos who throw Rule 11 around without knowing what they are doing.


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