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Old February 19th 10, 01:03 AM posted to rec.games.chess.politics
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First recorded activity by ChessBanter: Jun 2009
Posts: 406
Default roberts draft complaint #1

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
EL PASO DIVISION


MARCUS WAYNE ROBERTS
Plaintiff.


V. Civil Action No.


THE HONORABLE ABIGAIL ORTEGA,
County & District Court Clerk for Hudspeth County, Texas;
HUDSPETH COUNTY, TEXAS.

WRIT OF MANDAMUS AND COMPLAINT FOR DAMAGES AND REQUEST FOR NEW
ELECTIONS

Plaintiff seeks writ of mandamus ordering Clerk Ortega to record
documents relating to plaintiff's homestead to protect his United
States Citizenship.(Roberts v. Clinton 3:10-cv-00050-KC , filed in the
Western District of Texas). Plaintiff seeks WRIT ordering Clerk to
send Plaintiff absentee ballot. Clerk Ortega refuses to send plaintiff
absentee voting ballot after submitting three requests, and requests
plaintiff and other Hudspeth County voters fill out additional
absentee ballot requests. Plaintiff seeks ORDER DELAYING March 2, 2010
primary elections or ELECTIONS due to failure of Abigail Ortega to
send ABSENTEE BALLOT TO PLANTIFF AND OTHER CITIZENS of Hudspeth
County, Texas. Plaintiff seeks to qualify as Democratic Candidate for
Hudspeth County, Judge in delayed primary elections. Defendants seek
to deny candidates associated with Black people (Roberts serves as
Ambassador or former Ambassador of St Kitts and Nevis) ballots in the
elections.

PARITIES

Marcus Wayne Roberts, Plaintiff, PO BOX 961029, El Paso, Texas.
Plaintiff seeks to protect his United States citizenship, see fair
county elections held, and to qualify in the Democratic primary in
delayed elections.

Defendant Abigail Ortega is the Clerk of the County and District
Courts for Hudspeth County, Texas. She is improperly manipulating the
absentee ballots in one of the smallest counties in Texas. In 2008,
only 1,631 people were registered to vote, 898 voted, and 280 voted
early, according to http://www.sos.state.tx.us/elections...hudspeth.shtml.

Defendant Hudspeth County Texas is a political subdivision of the
State of Texas. The county is served to empower the court to hold new
elections.



JURISDICTION

The Western District of Texas District Court has jurisdiction to
grant Roberts Petition for Writ of Mandamus pursuant to Article V,
Section 3 of the Texas Constitution and Texas
Government Code 5 22.002 (2005). This is a civil action over which
this Court has jurisdiction under 28 U.S.C. 1331 (federal question),
due to Roberts suit against Secretary of State Clinton with regard to
his United States Citizenship (Roberts v. Clinton 3:10-cv-00050-KC ,
filed in the Western District of Texas). Furthermore, the National
Voting Rights Act of 1965 (42 U.S.C. 19731973aa-6)[1] outlawed
discriminatory voting practices that had been responsible for the
widespread disenfranchisement of African Americans in the United
States. Echoing the language of the 15th Amendment, the Act prohibited
states from imposing any "voting qualification or prerequisite to
voting, or standard, practice, or procedure ... to deny or abridge the
right of any citizen of the United States to vote on account of race
or color." Furthermore, 28 USC 2201-2202 (Declaratory Judgment Act) 5
U.S.C. 701 et seq (Administrative Procedure Act- to compel agency
action unlawfully withheld or unreasonably delayed) and 5 U.S.C.
Section 2412(d) (Equal Access to Justice Act) gives jurisdiction.
Jurisdiction also comes from the fifth and fourteenth, and 15th
amendments of the US Constitution. Finally, jurisdiction comes from
the National Voter Registration Act of 1993 (also known as the "NVRA"
and the "Motor Voter Act"), to enhance voting opportunities for every
American. The Act has made it easier for all Americans to register to
vote and to maintain their registration. Jurisdiction to order the
clerk to record specific records comes from the following Texas
statues:

1201.205. STATEMENT OF OWNERSHIP AND LOCATION. A
statement of ownership and location must provide:
(1) the names and addresses of the purchaser and
seller;
(2) the manufacturer's name and address and any
model
designation;
(3) in accordance with the director's
rules:
(A) the outside dimensions of the
manufactured
home when installed for occupancy, as measured to the nearest
one-half foot at the base of the home, exclusive of the tongue or
other towing device; and
(B) the approximate square footage of the
home
when installed for occupancy;
(4) the identification number for each section or
module of the home;
(5) the county of this state in which the home is
installed for occupancy;
(6) in chronological order of recordation, the date
of
each lien on the home and the name and address of each lienholder,
or, if a lien is not recorded, a statement of that fact;
(7) the signature of the owner in ink, given on
receipt
of the document;
(8) a statement that if two or more eligible
persons,
as determined by Section 1201.213, file with the application for
the issuance of a statement of ownership and location an agreement
signed by all the persons providing that the home is to be held
jointly with a right of survivorship, the director shall issue the
statement of ownership and location in all the names;
(9) the location of the
home;
(10) a statement of whether the owner has elected to
treat the home as real property or personal property;
(11) statements of whether the home is a salvaged
manufactured home and whether the home is reserved for business use
only; and
(12) any other information the director
requires.
Added by Acts 2001, 77th Leg., ch. 1421, 2, eff. June 1, 2003.
Amended by Acts 2003, 78th Leg., ch. 338, 13, eff. June 18,
2003.
1201.2055. ELECTION BY OWNER. (a) In completing an
application for the issuance of a statement of ownership and
location, an owner of a manufactured home shall indicate whether
the owner elects to treat the home as personal property or real
property. An owner may elect to treat a manufactured home as real
property only if the home is attached to:
(1) real property that is owned by the owner of the
home; or
(2) land leased to the owner of the home under a
long-term lease, as defined by department rule.
(b) A statement of election under Subsection (a) must be
made by affidavit.
(c) If the department issues a statement of ownership and
location to an owner who has elected to treat a manufactured home as
personal property, the statement of ownership and location on file
with the department is evidence of ownership of the home. A lien,
charge, or other encumbrance on a home treated as personal property
may be made only by filing the appropriate document with the
department.
(d) If an owner elects to treat a manufactured home as real
property, the department shall issue to the owner a certified copy
of the statement of ownership and location that on its face reflects
that the owner has elected to treat the manufactured home as real
property at the location listed on the statement. Not later than
the 60th day after the date the department issues a certified copy
of the statement of ownership and location to the owner, the owner
must:
(1) file the certified copy in the real property
records of the county in which the home is located; and
(2) notify the department and the tax
assessor-collector that the certified copy has been filed.
(e) A manufactured home is not considered to be real
property until a certified copy of the statement of ownership and
location has been filed and the department and the tax
assessor-collector have been notified of the filing as provided by
Subsection (d).

CHAPTER 12. RECORDING OF INSTRUMENTS
Sec. 12.001. INSTRUMENTS CONCERNING PROPERTY. (a)PROPERTY CODE
TITLE 3. PUBLIC RECORDS
CHAPTER 12. RECORDING OF INSTRUMENTS
Sec. 12.001. INSTRUMENTS CONCERNING PROPERTY. (a) An instrument
concerning real or personal property may be recorded if it has been
acknowledged, sworn to with a proper jurat, or proved according to
law.
(b) An instrument conveying real property may not be recorded unless
it is signed and acknowledged or sworn to by the grantor in the
presence of two or more credible subscribing witnesses or
acknowledged
or sworn to before and certified by an officer authorized to take
acknowledgements or oaths, as applicable.
(c) This section does not require the acknowledgement or swearing or
prohibit the recording of a financing statement, a security agreement
filed as a financing statement, or a continuation statement filed for
record under the Business & Commerce Code.
(d) The failure of a notary public to attach an official seal to an
acknowledgment, a jurat, or other proof taken outside this state but
inside the United States or its territories renders the
acknowledgment, jurat, or other proof invalid only if the
jurisdiction
in which the acknowledgment, jurat, or other proof is taken requires
the notary public to attach the seal.
Acts 1983, 68th Leg., p. 3489, ch. 576, Sec. 1, eff. Jan. 1, 1984.
Amended by Acts 1989, 71st Leg., ch. 162, Sec. 2, eff. Sept. 1, 1989;
Acts 1995, 74th Leg., ch. 603, Sec. 2, eff. June 14, 1995.
Sec. 12.0011. INSTRUMENTS CONCERNING PROPERTY: ORIGINAL SIGNATURE
REQUIRED FOR CERTAIN INSTRUMENTS. (a) For the purposes of this
section, "paper document" means a document received by a county clerk
in a form that is not electronic.
(b) A paper document concerning real or personal property may not be
recorded or serve as notice of the paper document unless:
(1) the paper document contains an original signature or signatures
that are acknowledged, sworn to with a proper jurat, or proved
according to law; or
(2) the paper document is attached as an exhibit to a paper
affidavit
or other document that has an original signature or signatures that
are acknowledged, sworn to with a proper jurat, or proved according
to
law.
(c) An original signature may not be required for an electronic
instrument or other document that complies with the requirements of
Chapter 15 of this code, Chapter 195, Local Government Code, Chapter
43, Business & Commerce Code, or other applicable law.
..
(b) An instrument conveying real property may not be recorded unless
it is signed and acknowledged or sworn to by the grantor in the
presence of two or more credible subscribing witnesses or
acknowledged
or sworn to before and certified by an officer authorized to take
acknowledgements or oaths, as applicable.
(c) This section does not require the acknowledgement or swearing or
prohibit the recording of a financing statement, a security agreement
filed as a financing statement, or a continuation statement filed for
record under the Business & Commerce Code.
(d) The failure of a notary public to attach an official seal to an
acknowledgment, a jurat, or other proof taken outside this state but
inside the United States or its territories renders the
acknowledgment, jurat, or other proof invalid only if the
jurisdiction
in which the acknowledgment, jurat, or other proof is taken requires
the notary public to attach the seal.
Acts 1983, 68th Leg., p. 3489, ch. 576, Sec. 1, eff. Jan. 1, 1984.
Amended by Acts 1989, 71st Leg., ch. 162, Sec. 2, eff. Sept. 1, 1989;
Acts 1995, 74th Leg., ch. 603, Sec. 2, eff. June 14, 1995.
Sec. 12.0011. INSTRUMENTS CONCERNING PROPERTY: ORIGINAL SIGNATURE
REQUIRED FOR CERTAIN INSTRUMENTS. (a) For the purposes of this
section, "paper document" means a document received by a county clerk
in a form that is not electronic.
(b) A paper document concerning real or personal property may not be
recorded or serve as notice of the paper document unless:
(1) the paper document contains an original signature or signatures
that are acknowledged, sworn to with a proper jurat, or proved
according to law; or
(2) the paper document is attached as an exhibit to a paper
affidavit
or other document that has an original signature or signatures that
are acknowledged, sworn to with a proper jurat, or proved according
to
law.
(c) An original signature may not be required for an electronic
instrument or other document that complies with the requirements of
Chapter 15 of this code, Chapter 195, Local Government Code, Chapter
43, Business & Commerce Code, or other applicable law.

VENUE


Hudspeth County, Texas and the Clerk and the Plaintiff all are closest
to the El Paso Division of the Western District of Texas.

REQUEST FOR COMPENSATORY AND PUNATIVE DAMAGES

Plaintiff seeks damages for DECEPTIVE TRADE PRATICES (unspecified and
TRIPLE) and toutious interference of his ability to sell his homestead
against both defendants. Plaintiff lacks fair title marketability due
to lack of title policy in the public records. Plaintiff has a right
to record title policy. Plaintiff has no ability to record title to
his home, or any other documents concerning his homestead, without
paying a BRIBE to the Clerk of the Court, or County Attorney, who
intends to prosecute him for a class "B" misdemeanor.

Filed this 20 day of February, 2010



Marcus Wayne Roberts
PRO SE

PO BOX 961029
El Paso, Texas 79996
915-988-2530

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Old February 19th 10, 01:12 AM posted to rec.games.chess.politics
external usenet poster
 
First recorded activity by ChessBanter: Jun 2009
Posts: 406
Default roberts draft complaint #1

draft #2 - I will file Saturday morning.

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
EL PASO DIVISION


MARCUS WAYNE ROBERTS
Plaintiff.


V. Civil Action No.


THE HONORABLE ABIGAIL ORTEGA,
County & District Court Clerk for Hudspeth County, Texas;
HUDSPETH COUNTY, TEXAS.

WRIT OF MANDAMUS AND COMPLAINT FOR DAMAGES AND REQUEST FOR NEW
ELECTIONS

Plaintiff seeks writ of mandamus ordering Clerk Ortega to record
documents relating to plaintiff's homestead to protect his United
States Citizenship.(Roberts v. Clinton 3:10-cv-00050-KC , filed in the
Western District of Texas). Plaintiff seeks WRIT ordering Clerk to
send Plaintiff absentee ballot. Clerk Ortega refuses to send plaintiff
absentee voting ballot after submitting three requests, and requests
plaintiff and other Hudspeth County voters fill out additional
absentee ballot requests. Plaintiff seeks ORDER DELAYING March 2, 2010
primary elections or ELECTIONS due to failure of Abigail Ortega to
send ABSENTEE BALLOT TO PLANTIFF AND OTHER CITIZENS of Hudspeth
County, Texas. Plaintiff seeks to qualify as Democratic Candidate for
Hudspeth County, Judge in delayed primary elections. Defendants seek
to deny candidates associated with Black people (Roberts serves as
Ambassador or former Ambassador of St Kitts and Nevis) ballots in the
elections.

PARITIES

Marcus Wayne Roberts, Plaintiff, PO BOX 961029, El Paso, Texas.
Plaintiff seeks to protect his United States citizenship, see fair
county elections held, and to qualify in the Democratic primary in
delayed elections.

Defendant Abigail Ortega is the Clerk of the County and District
Courts for Hudspeth County, Texas. She is improperly manipulating the
absentee ballots in one of the smallest counties in Texas. In 2008,
only 1,631 people were registered to vote, 898 voted, and 280 voted
early, according to http://www.sos.state.tx.us/elections...hudspeth.shtml.

Defendant Hudspeth County Texas is a political subdivision of the
State of Texas. The county is served to empower the court to hold new
elections.



JURISDICTION

The Western District of Texas District Court has jurisdiction to
grant Roberts Petition for Writ of Mandamus pursuant to Article V,
Section 3 of the Texas Constitution and Texas
Government Code 5 22.002 (2005). This is a civil action over which
this Court has jurisdiction under 28 U.S.C. 1331 (federal question),
due to Roberts suit against Secretary of State Clinton with regard to
his United States Citizenship (Roberts v. Clinton 3:10-cv-00050-KC ,
filed in the Western District of Texas). Furthermore, the National
Voting Rights Act of 1965 (42 U.S.C. 19731973aa-6)[1] outlawed
discriminatory voting practices that had been responsible for the
widespread disenfranchisement of African Americans in the United
States. Echoing the language of the 15th Amendment, the Act prohibited
states from imposing any "voting qualification or prerequisite to
voting, or standard, practice, or procedure ... to deny or abridge the
right of any citizen of the United States to vote on account of race
or color." Furthermore, 28 USC 2201-2202 (Declaratory Judgment Act) 5
U.S.C. 701 et seq (Administrative Procedure Act- to compel agency
action unlawfully withheld or unreasonably delayed) and 5 U.S.C.
Section 2412(d) (Equal Access to Justice Act) gives jurisdiction.
Jurisdiction also comes from the fifth and fourteenth, and 15th
amendments of the US Constitution. Finally, jurisdiction comes from
the National Voter Registration Act of 1993 (also known as the "NVRA"
and the "Motor Voter Act"), to enhance voting opportunities for every
American. The Act has made it easier for all Americans to register to
vote and to maintain their registration. Jurisdiction to order the
clerk to record specific records comes from the following Texas
statues:

Texas Occupations Code - Section 1201.205. Statement Of Ownership And
Location
1201.205. STATEMENT OF OWNERSHIP AND LOCATION. A
statement of ownership and location must provide:
(1) the names and addresses of the purchaser and
seller;
(2) the manufacturer's name and address and any
model
designation;
(3) in accordance with the director's
rules:
(A) the outside dimensions of the
manufactured
home when installed for occupancy, as measured to the nearest
one-half foot at the base of the home, exclusive of the tongue or
other towing device; and
(B) the approximate square footage of the
home
when installed for occupancy;
(4) the identification number for each section or
module of the home;
(5) the county of this state in which the home is
installed for occupancy;
(6) in chronological order of recordation, the date
of
each lien on the home and the name and address of each lienholder,
or, if a lien is not recorded, a statement of that fact;
(7) the signature of the owner in ink, given on
receipt
of the document;
(8) a statement that if two or more eligible
persons,
as determined by Section 1201.213, file with the application for
the issuance of a statement of ownership and location an agreement
signed by all the persons providing that the home is to be held
jointly with a right of survivorship, the director shall issue the
statement of ownership and location in all the names;
(9) the location of the
home;
(10) a statement of whether the owner has elected to
treat the home as real property or personal property;
(11) statements of whether the home is a salvaged
manufactured home and whether the home is reserved for business use
only; and
(12) any other information the director
requires.
Added by Acts 2001, 77th Leg., ch. 1421, 2, eff. June 1, 2003.
Amended by Acts 2003, 78th Leg., ch. 338, 13, eff. June 18,
2003.
1201.2055. ELECTION BY OWNER. (a) In completing an
application for the issuance of a statement of ownership and
location, an owner of a manufactured home shall indicate whether
the owner elects to treat the home as personal property or real
property. An owner may elect to treat a manufactured home as real
property only if the home is attached to:
(1) real property that is owned by the owner of the
home; or
(2) land leased to the owner of the home under a
long-term lease, as defined by department rule.
(b) A statement of election under Subsection (a) must be
made by affidavit.
(c) If the department issues a statement of ownership and
location to an owner who has elected to treat a manufactured home as
personal property, the statement of ownership and location on file
with the department is evidence of ownership of the home. A lien,
charge, or other encumbrance on a home treated as personal property
may be made only by filing the appropriate document with the
department.
(d) If an owner elects to treat a manufactured home as real
property, the department shall issue to the owner a certified copy
of the statement of ownership and location that on its face reflects
that the owner has elected to treat the manufactured home as real
property at the location listed on the statement. Not later than
the 60th day after the date the department issues a certified copy
of the statement of ownership and location to the owner, the owner
must:
(1) file the certified copy in the real property
records of the county in which the home is located; and
(2) notify the department and the tax
assessor-collector that the certified copy has been filed.
(e) A manufactured home is not considered to be real
property until a certified copy of the statement of ownership and
location has been filed and the department and the tax
assessor-collector have been notified of the filing as provided by
Subsection (d).
Sec. 12.001. INSTRUMENTS CONCERNING PROPERTY. (a) TITLE 3. PUBLIC
RECORDS
PROPERTY CODE
CHAPTER 12. RECORDING OF INSTRUMENTS
Sec. 12.001. INSTRUMENTS CONCERNING PROPERTY. (a) An instrument
concerning real or personal property may be recorded if it has been
acknowledged, sworn to with a proper jurat, or proved according to
law.
(b) An instrument conveying real property may not be recorded unless
it is signed and acknowledged or sworn to by the grantor in the
presence of two or more credible subscribing witnesses or
acknowledged
or sworn to before and certified by an officer authorized to take
acknowledgements or oaths, as applicable.
(c) This section does not require the acknowledgement or swearing or
prohibit the recording of a financing statement, a security agreement
filed as a financing statement, or a continuation statement filed for
record under the Business & Commerce Code.
(d) The failure of a notary public to attach an official seal to an
acknowledgment, a jurat, or other proof taken outside this state but
inside the United States or its territories renders the
acknowledgment, jurat, or other proof invalid only if the
jurisdiction
in which the acknowledgment, jurat, or other proof is taken requires
the notary public to attach the seal.
Acts 1983, 68th Leg., p. 3489, ch. 576, Sec. 1, eff. Jan. 1, 1984.
Amended by Acts 1989, 71st Leg., ch. 162, Sec. 2, eff. Sept. 1, 1989;
Acts 1995, 74th Leg., ch. 603, Sec. 2, eff. June 14, 1995.
Sec. 12.0011. INSTRUMENTS CONCERNING PROPERTY: ORIGINAL SIGNATURE
REQUIRED FOR CERTAIN INSTRUMENTS. (a) For the purposes of this
section, "paper document" means a document received by a county clerk
in a form that is not electronic.
(b) A paper document concerning real or personal property may not be
recorded or serve as notice of the paper document unless:
(1) the paper document contains an original signature or signatures
that are acknowledged, sworn to with a proper jurat, or proved
according to law; or
(2) the paper document is attached as an exhibit to a paper
affidavit
or other document that has an original signature or signatures that
are acknowledged, sworn to with a proper jurat, or proved according
to
law.
(c) An original signature may not be required for an electronic
instrument or other document that complies with the requirements of
Chapter 15 of this code, Chapter 195, Local Government Code, Chapter
43, Business & Commerce Code, or other applicable law.
..
(b) An instrument conveying real property may not be recorded unless
it is signed and acknowledged or sworn to by the grantor in the
presence of two or more credible subscribing witnesses or
acknowledged
or sworn to before and certified by an officer authorized to take
acknowledgements or oaths, as applicable.
(c) This section does not require the acknowledgement or swearing or
prohibit the recording of a financing statement, a security agreement
filed as a financing statement, or a continuation statement filed for
record under the Business & Commerce Code.
(d) The failure of a notary public to attach an official seal to an
acknowledgment, a jurat, or other proof taken outside this state but
inside the United States or its territories renders the
acknowledgment, jurat, or other proof invalid only if the
jurisdiction
in which the acknowledgment, jurat, or other proof is taken requires
the notary public to attach the seal.
Acts 1983, 68th Leg., p. 3489, ch. 576, Sec. 1, eff. Jan. 1, 1984.
Amended by Acts 1989, 71st Leg., ch. 162, Sec. 2, eff. Sept. 1, 1989;
Acts 1995, 74th Leg., ch. 603, Sec. 2, eff. June 14, 1995.
Sec. 12.0011. INSTRUMENTS CONCERNING PROPERTY: ORIGINAL SIGNATURE
REQUIRED FOR CERTAIN INSTRUMENTS. (a) For the purposes of this
section, "paper document" means a document received by a county clerk
in a form that is not electronic.
(b) A paper document concerning real or personal property may not be
recorded or serve as notice of the paper document unless:
(1) the paper document contains an original signature or signatures
that are acknowledged, sworn to with a proper jurat, or proved
according to law; or
(2) the paper document is attached as an exhibit to a paper
affidavit
or other document that has an original signature or signatures that
are acknowledged, sworn to with a proper jurat, or proved according
to
law.
(c) An original signature may not be required for an electronic
instrument or other document that complies with the requirements of
Chapter 15 of this code, Chapter 195, Local Government Code, Chapter
43, Business & Commerce Code, or other applicable law.

VENUE


Hudspeth County, Texas and the Clerk and the Plaintiff all are closest
to the El Paso Division of the Western District of Texas.

REQUEST FOR COMPENSATORY AND PUNATIVE DAMAGES

Plaintiff seeks damages for DECEPTIVE TRADE PRATICES (unspecified and
TRIPLE) and toutious interference of his ability to sell his homestead
against both defendants. Plaintiff lacks fair title marketability due
to lack of title policy in the public records. Plaintiff has a right
to record title policy. Plaintiff has no ability to record title to
his home, or any other documents concerning his homestead, without
paying a BRIBE to the Clerk of the Court, or County Attorney, who
intends to prosecute him for a class "B" misdemeanor.

Submitted this 20 day of February 2010




Marcus Wayne Roberts
PRO SE

PO BOX 961029
El Paso, Texas 79996
915-988-2530

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Old February 19th 10, 02:56 AM posted to rec.games.chess.politics
external usenet poster
 
First recorded activity by ChessBanter: Oct 2009
Posts: 112
Default roberts draft complaint #1

On Feb 18, 8:12*pm, NONE wrote:

Are you still talking?
  #4   Report Post  
Old February 19th 10, 03:17 AM posted to rec.games.chess.politics
external usenet poster
 
First recorded activity by ChessBanter: Nov 2009
Posts: 360
Default roberts draft complaint #1

On Feb 18, 6:03*pm, NONE wrote:
UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
EL PASO DIVISION

MARCUS WAYNE ROBERTS
Plaintiff.

V. * * * * * * * * * * * * * * * * * * * * * * * * * * * *Civil Action No.

THE HONORABLE ABIGAIL ORTEGA,
*County & District Court Clerk for Hudspeth County, Texas;
HUDSPETH COUNTY, TEXAS.

WRIT OF MANDAMUS AND COMPLAINT FOR DAMAGES AND REQUEST FOR NEW
ELECTIONS

Plaintiff seeks writ of mandamus ordering Clerk Ortega to record
documents relating to plaintiff's homestead to protect his United
States Citizenship.(Roberts v. Clinton 3:10-cv-00050-KC , filed in the
Western District of Texas). Plaintiff seeks WRIT ordering Clerk to
send Plaintiff absentee ballot. Clerk Ortega refuses to send plaintiff
absentee voting ballot after submitting three requests, and requests
plaintiff and other Hudspeth County voters fill out additional
absentee ballot requests. Plaintiff seeks ORDER DELAYING March 2, 2010
primary elections or ELECTIONS due to failure of Abigail Ortega to


Hey Einstein, I have a question for you: How can you order "New
Elections" when the Election is not due to happen till March 2nd
2010?!? While you are trying to understand that simple question,
maybe you can enlighten us all with how your suit against Hillary
Clinton figures into this, and what no mention of DHS?!? They really
must feel left out!!! Maybe you need to revise this cheap suit so DHS
is likewise included. You REALLY should have stayed in Law School!!!!
  #5   Report Post  
Old February 19th 10, 04:05 PM posted to rec.games.chess.politics
external usenet poster
 
First recorded activity by ChessBanter: Jun 2009
Posts: 406
Default roberts draft complaint #1

On Feb 18, 8:17*pm, Bobcat wrote:
On Feb 18, 6:03*pm, NONE wrote:





UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
EL PASO DIVISION


MARCUS WAYNE ROBERTS
Plaintiff.


V. * * * * * * * * * * * * * * * * * * * * * * * * * * * *Civil Action No.


THE HONORABLE ABIGAIL ORTEGA,
*County & District Court Clerk for Hudspeth County, Texas;
HUDSPETH COUNTY, TEXAS.


WRIT OF MANDAMUS AND COMPLAINT FOR DAMAGES AND REQUEST FOR NEW
ELECTIONS


Plaintiff seeks writ of mandamus ordering Clerk Ortega to record
documents relating to plaintiff's homestead to protect his United
States Citizenship.(Roberts v. Clinton 3:10-cv-00050-KC , filed in the
Western District of Texas). Plaintiff seeks WRIT ordering Clerk to
send Plaintiff absentee ballot. Clerk Ortega refuses to send plaintiff
absentee voting ballot after submitting three requests, and requests
plaintiff and other Hudspeth County voters fill out additional
absentee ballot requests. Plaintiff seeks ORDER DELAYING March 2, 2010
primary elections or ELECTIONS due to failure of Abigail Ortega to


Hey Einstein, I have a question for you: How can you order "New
Elections" when the Election is not due to happen till March 2nd
2010?!? *While you are trying to understand that simple question,
maybe you can enlighten us all with how your suit against Hillary
Clinton figures into this, and what no mention of DHS?!? They really
must feel left out!!! Maybe you need to revise this cheap suit so DHS
is likewise included. You REALLY should have stayed in Law School!!!!- Hide quoted text -

- Show quoted text -


How many children do you molest, Bobcat? Are you Paul Troung? Are you
and Susan molesting children.
Why don't you sue you MOTHER ****ER, so I can get you fired at TExas
Tech.

Marcus Roberts
Ambassador of St Kitts and Nevis


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Old February 19th 10, 04:06 PM posted to rec.games.chess.politics
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First recorded activity by ChessBanter: Jun 2009
Posts: 406
Default roberts draft complaint #1

On Feb 18, 6:12*pm, NONE wrote:
draft #2 - *I will file Saturday morning.

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF TEXAS
EL PASO DIVISION

MARCUS WAYNE ROBERTS
Plaintiff.

V. * * * * * * * * * * * * * * * * * * * * * * * * * * * *Civil Action No.

THE HONORABLE ABIGAIL ORTEGA,
*County & District Court Clerk for Hudspeth County, Texas;
HUDSPETH COUNTY, TEXAS.

WRIT OF MANDAMUS AND COMPLAINT FOR DAMAGES AND REQUEST FOR NEW
ELECTIONS

Plaintiff seeks writ of mandamus ordering Clerk Ortega to record
documents relating to plaintiff's homestead to protect his United
States Citizenship.(Roberts v. Clinton 3:10-cv-00050-KC , filed in the
Western District of Texas). Plaintiff seeks WRIT ordering Clerk to
send Plaintiff absentee ballot. Clerk Ortega refuses to send plaintiff
absentee voting ballot after submitting three requests, and requests
plaintiff and other Hudspeth County voters fill out additional
absentee ballot requests. Plaintiff seeks ORDER DELAYING March 2, 2010
primary elections or ELECTIONS due to failure of Abigail Ortega to
send ABSENTEE BALLOT TO PLANTIFF AND OTHER CITIZENS of Hudspeth
County, Texas. Plaintiff seeks to qualify as Democratic Candidate for
Hudspeth County, Judge in delayed primary elections. Defendants seek
to deny candidates associated with Black people (Roberts serves as
Ambassador or former Ambassador of St Kitts and Nevis) ballots in the
elections.

PARITIES

Marcus Wayne Roberts, Plaintiff, PO BOX 961029, El Paso, Texas.
Plaintiff seeks to protect his United States citizenship, see fair
county elections held, and to qualify in the Democratic primary in
delayed elections.

Defendant Abigail Ortega is the Clerk of the County and District
Courts for Hudspeth County, Texas. She is improperly manipulating the
absentee ballots in one of the smallest counties in Texas. In 2008,
only 1,631 people were registered to vote, 898 voted, and 280 voted
early, according tohttp://www.sos.state.tx.us/elections/historical/hudspeth.shtml.

Defendant *Hudspeth County Texas is a political subdivision of the
State of Texas. The county is served to empower the court to hold new
elections.

JURISDICTION

The Western District of Texas District Court has jurisdiction to
grant *Roberts Petition for Writ of Mandamus pursuant to Article V,
Section 3 of the Texas Constitution and Texas
Government Code 5 22.002 (2005). This is a civil action over which
this Court has jurisdiction under 28 U.S.C. 1331 (federal question),
due to Roberts suit against Secretary of State Clinton with regard to
his United States Citizenship (Roberts v. Clinton 3:10-cv-00050-KC ,
filed in the Western District of Texas). Furthermore, the National
Voting Rights Act of 1965 (42 U.S.C. 19731973aa-6)[1] outlawed
discriminatory voting practices that had been responsible for the
widespread disenfranchisement of African Americans in the United
States. Echoing the language of the 15th Amendment, the Act prohibited
states from imposing any "voting qualification or prerequisite to
voting, or standard, practice, or procedure ... to deny or abridge the
right of any citizen of the United States to vote on account of race
or color." Furthermore, 28 USC 2201-2202 (Declaratory Judgment Act) 5
U.S.C. 701 et seq (Administrative Procedure Act- to compel agency
action unlawfully withheld or unreasonably delayed) and 5 U.S.C.
Section 2412(d) (Equal Access to Justice Act) gives jurisdiction.
Jurisdiction also comes from the fifth and fourteenth, and 15th
amendments of the US Constitution. Finally, jurisdiction comes from
the National Voter Registration Act of 1993 (also known as the "NVRA"
and the "Motor Voter Act"), to enhance voting opportunities for every
American. The Act has made it easier for all Americans to register to
vote and to maintain their registration. Jurisdiction to order the
clerk to record specific records comes from the following Texas
statues:

Texas Occupations Code - Section 1201.205. Statement Of Ownership And
Location
1201.205. STATEMENT OF OWNERSHIP AND LOCATION. *A
statement of ownership and location must provide:
* * * * * * * * (1) *the names and addresses of the purchaser and
seller;
* * * * * * * * (2) *the manufacturer's name and address and any
model
designation;
* * * * * * * * (3) *in accordance with the director's
rules:
* * * * * * * * * * * * (A) *the outside dimensions of the
manufactured
home when installed for occupancy, as measured to the nearest
one-half foot at the base of the home, exclusive of the tongue or
other towing device; *and
* * * * * * * * * * * * (B) *the approximate square footage of the
home
when installed for occupancy;
* * * * * * * * (4) *the identification number for each section or
module of the home;
* * * * * * * * (5) *the county of this state in which the home is
installed for occupancy;
* * * * * * * * (6) *in chronological order of recordation, the date
of
each lien on the home and the name and address of each lienholder,
or, if a lien is not recorded, a statement of that fact;
* * * * * * * * (7) *the signature of the owner in ink, given on
receipt
of the document;
* * * * * * * * (8) *a statement that if two or more eligible
persons,
as determined by Section 1201.213, file with the application for
the issuance of a statement of ownership and location an agreement
signed by all the persons providing that the home is to be held
jointly with a right of survivorship, the director shall issue the
statement of ownership and location in all the names;
* * * * * * * * (9) *the location of the
home;
* * * * * * * * (10) *a statement of whether the owner has elected to
treat the home as real property or personal property;
* * * * * * * * (11) *statements of whether the home is a salvaged
manufactured home and whether the home is reserved for business use
only; *and
* * * * * * * * (12) *any other information the director
requires.
Added by Acts 2001, 77th Leg., ch. 1421, 2, eff. June 1, 2003.
Amended by Acts 2003, 78th Leg., ch. 338, 13, eff. June 18,
2003.
* * * * 1201.2055. ELECTION BY OWNER. *(a) In completing an
application for the issuance of a statement of ownership and
location, an owner of a manufactured home shall indicate whether
the owner elects to treat the home as personal property or real
property. *An owner may elect to treat a manufactured home as real
property only if the home is attached to:
* * * * * * * * (1) *real property that is owned by the owner of the
home; *or
* * * * * * * * (2) *land leased to the owner of the home under a
long-term lease, as defined by department rule.
* * * * (b) *A statement of election under Subsection (a) must be
made by affidavit.
* * * * (c) *If the department issues a statement of ownership and
location to an owner who has elected to treat a manufactured home as
personal property, the statement of ownership and location on file
with the department is evidence of ownership of the home. *A lien,
charge, or other encumbrance on a home treated as personal property
may be made only by filing the appropriate document with the
department.
* * * * (d) *If an owner elects to treat a manufactured home as real
property, the department shall issue to the owner a certified copy
of the statement of ownership and location that on its face reflects
that the owner has elected to treat the manufactured home as real
property at the location listed on the statement. *Not later than
the 60th day after the date the department issues a certified copy
of the statement of ownership and location to the owner, the owner
must:
* * * * * * * * (1) *file the certified copy in the real property
records of the county in which the home is located; *and
* * * * * * * * (2) *notify the department and the tax
assessor-collector that the certified copy has been filed.
* * * * (e) *A manufactured home is not considered to be real
property until a certified copy of the statement of ownership and
location has been filed and the department and the tax
assessor-collector have been notified of the filing as provided by
Subsection (d).
Sec. 12.001. *INSTRUMENTS CONCERNING PROPERTY. *(a) TITLE 3. PUBLIC
RECORDS
PROPERTY CODE
CHAPTER 12. RECORDING OF INSTRUMENTS
Sec. 12.001. *INSTRUMENTS CONCERNING PROPERTY. *(a) *An instrument
concerning real or personal property may be recorded if it has been
acknowledged, sworn to with a proper jurat, or proved according to
law.
(b) *An instrument conveying real property may not be recorded unless
it is signed and acknowledged or sworn to by the grantor in the
presence of two or more credible subscribing witnesses or
acknowledged
or sworn to before and certified by an officer authorized to take
acknowledgements or oaths, as applicable.
(c) *This section does not require the acknowledgement or swearing or
prohibit the recording of a financing statement, a security agreement
filed as a financing statement, or a continuation statement filed for
record under the Business & Commerce Code.
(d) *The failure of a notary public to attach an official seal to an
acknowledgment, a jurat, or other proof taken outside this state but
inside the United States or its territories renders the
acknowledgment, jurat, or other proof invalid only if the
jurisdiction
in which the acknowledgment, jurat, or other proof is taken requires
the notary public to attach the seal.
Acts 1983, 68th Leg., p. 3489, ch. 576, Sec. 1, eff. Jan. 1, 1984.
Amended by Acts 1989, 71st Leg., ch. 162, Sec. 2, eff. Sept. 1, 1989;
Acts 1995, 74th Leg., ch. 603, Sec. 2, eff. June 14, 1995.
Sec. 12.0011. *INSTRUMENTS CONCERNING PROPERTY: ORIGINAL SIGNATURE
REQUIRED FOR CERTAIN INSTRUMENTS. *(a) *For the purposes of this
section, "paper document" means a document received by a county clerk
in a form that is not electronic.
(b) *A paper document concerning real or personal property may not be
recorded or serve as notice of the paper document unless:
(1) *the paper document contains an original signature or signatures
that are acknowledged, sworn to with a proper jurat, or proved
according to law; or
(2) *the paper document is attached as
...

read more


MOTIONS AND REQUESTS TO COURT
1. Plaintiff requests leave of the court to file amended complaint
after discovery.
2. Plaintiff requests Judge Martinez NOT be assigned to this case due
to motion to disqualify pending in Roberts v. Rio Grande Electric
Cooperative, et. al. Case Number. 3:09-cv-00403-PRM
3. Plaintiff requests all hearings. Plaintiff is unable to enter
courthouse due to dispute with Judge Martinez. Plaintiff invokes fifth
amended on all questions concerning terrorist threats against Rio
Grande Electric Cooperative due to a pending class "B" misdemeanor
charge.

EXPLNATION OF ADDITIONAL PAGES INCLUDED

Copies of the title policy to be recorded, the a blank copy of the
voter registration Roberts filed out, faxed, and US mailed to the
voter register of Hudspeth County, and the return duplicate
application requested are filed for review of the court. The Texas
Department of Housing and Community Affairs is now preparing a real
property statement of ownership and location to be recorded in the
records of Hudspeth County, Texas. Copies of the Warranty Deed of
Roberts homestead are also included.
  #7   Report Post  
Old February 20th 10, 03:13 AM posted to rec.games.chess.politics
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First recorded activity by ChessBanter: Nov 2009
Posts: 360
Default roberts draft complaint #1


How many children do you molest, Bobcat? Are you Paul Troung? Are you
and Susan molesting children.
Why don't you sue you MOTHER ****ER, so I can get you fired at TExas
Tech.

Marcus Roberts
Ambassador of St Kitts and Nevis


Sorry Marcus, I'm not Paul Triung, don't live in TX, and like you (or
not) I'm a West Indian: I grew up eating sugar cane, skin and scuba
diving in water you could see the bottom 50 feet down, walking on
clean white beaches were the only foot prints I could see were my own,
listening to steel band music, dancing in the streets at 4 am Jovert
Morning, met Sparrow, Shadow, Calypso Rose, was once invited to dance
on stage with Singing Francine, and met many, many other truly great
calypsoians. All I can claim is I was born in the U.S. but that's
about it. I grew up, raised, and educated in the West Indies, and were
it not for an incurable and degenerative disease, I'd have no time to
reply to your silly rants, as I use to work a 12-16 hour day and truly
loved my work, now I live on SS. After 18 years I've developed an
American patina, but this is not my true home. If I were offered a
REAL living wage, and someone were willing to hire someone who will
need ongoing medical treatments for the remainder of their life, for
as long or short as it may be, know I'd be gone in an instant, and
never look back. But that is NOT realistic, and so I've learned to
live not in the past, as it has gone; or worry about a tomorrow that
may never come, or the horrors it may hold, as it has not come; but
rather to live in this present moment. As a friend, you need to get
HELP, and the sooner the better! Instead of filing these long tedious
lawsuits, which probably most people just laugh at, why not seek out a
mental health professional? Clearly you are not well. You are your own
worst enemy Marcus. Your future is your own, what you do with it is in
your hands -- not in the hands of anyone on this board; not in the
hands of Hillary Clinton; not in the hands of DHS; not in the hands of
the legal system; not in the hands of the Electric company; but rather
in your own hands. Be kind to yourself Marcus, get help now. There are
some exceptionally intelligent people who post here, who can been
friends or foes, who probably have high IQ's, and who wisdom suggests
should not be crossed. PLEASE SEEK HELP NOW!!!

Sincerely,

Bobcat
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