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Old March 31st 10, 01:38 AM posted to rec.games.chess.politics
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Posts: 406
Default draft of complaint

This isn't NSA, this is greed!

State of Texas
Hudspeth County 205th District Court


Marcus Wayne Roberts
Plaintiff.

v. Case number

Steward Title Guaranty, Co., A Texas Corporation
Defendant.

COMPLAINT


PARTIES

1. Marcus Wayne Roberts,
Plaintiff,
PO BOX 961029,
El Paso, Texas 79996

2. Steward Title Guaranty Co., A Texas Corporation,
1980 POST OAK BLVD STE 800
HOUSTON, TX 770563826

VENUE

3. This contract concerns plaintiff's homestead, located in Hudspeth
County, Texas.

JURISDICTION

4. Claims for deceptive trade practices could exceed 50,000 dollars.
District Court is appropriate.

LACK OF GOOD AND INDEFEASIBLE TITLE

5. This is an action of breach of contract, due to a certain title
policy O-5951-000004116 issued by the Defendant in September of 2009.
Defendants have refused to arbitrate, per clause 14 of the contract.

6. Defendant has insured Plaintiff in the amount of 30,000 dollars
GOOD AND INDEFEASIBLE TITLE, per the title contract attached to this
complaint.

7. "GOOD AND INDEFEASIBLE TITLE" never been legally defined, according
to TEXAS Real Estate Law 10e by Charles J. Jacobus, page 288.

8. Plaintiff is unable to build his dream home one of his three lots
due to a marketability error noted by the Defendant in schedule "B"
item "d" if his title policy:

Claims by the Tigua Indian Tribe of the Ysleta del Sur Pueblo, as
evidenced by that certain Affidavit concerning filing of Notice of
Claim to the Ysleta Grant and Aboriginal Title Areas, executed by
Julian Granillo, Governor of the Ysleta del Sur Pueblo Indian Tribe,
also known as the Tigua Indian Community, dated August 12, 1993, filed
on August 18, 1993, in Volume 195, Page 385, of the Deed Records of
Hudspeth County, Texas.

8. Plaintiff seeks to QUIET TITLE to improve property, because
DEFENDANT refuses to sell additional title insurance. Plaintiff can't
build on the land without risking his entire investment.

9. Plaintiff seeks TRIPLE DAMAGES for DECEPITVE TRADE PRATICES due to
the intentional failure of the Defendant to produce an ABSTRACT of the
PROPERTY so the PLANTIFF CAN QUIET TITLE.

10. Plaintiff is owed the amount of the title contract, or an
ABSTRACT, so the Plaintiff can quiet title.

11. Plaintiff seeks unspecified compensatory and punitive damages,
filing fees, and costs of service.


Marcus Wayne Roberts
PO BOX 961029
El Paso, Texas 79996
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Old March 31st 10, 01:50 AM posted to rec.games.chess.politics
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First recorded activity by ChessBanter: Jun 2009
Posts: 406
Default draft of complaint

State of Texas
Hudspeth County 205th District Court


Marcus Wayne Roberts
Plaintiff.

v. Case number

Steward Title Guaranty, Co., A Texas Corporation
Defendant.

COMPLAINT


PARTIES

1. Marcus Wayne Roberts,
Plaintiff,
PO BOX 961029,
El Paso, Texas 79996

2. Steward Title Guaranty Co., A Texas Corporation,
1980 POST OAK BLVD STE 800
HOUSTON, TX 770563826

VENUE

3. This contract concerns plaintiff's homestead, located in Hudspeth
County, Texas.

JURISDICTION

4. Claims for deceptive trade practices could exceed 50,000 dollars.
District Court is appropriate.

LACK OF GOOD AND INDEFEASIBLE TITLE

5. This is an action of breach of contract, due to a certain title
policy O-5951-000004116 issued by the Defendant in September of 2009.
Defendants have refused to arbitrate, per clause 14 of the contract.

6. Defendant has insured Plaintiff in the amount of 30,000 dollars
GOOD AND INDEFEASIBLE TITLE, per the title contract attached to this
complaint.

7. "GOOD AND INDEFEASIBLE TITLE" never been legally defined, according
to TEXAS Real Estate Law 10e by Charles J. Jacobus, page 288.

8. Plaintiff is unable to build his dream home one of his three lots
due to a marketability error noted by the Defendant in schedule "B"
item "d" if his title policy:

Claims by the Tigua Indian Tribe of the Ysleta del Sur Pueblo, as
evidenced by that certain Affidavit concerning filing of Notice of
Claim to the Ysleta Grant and Aboriginal Title Areas, executed by
Julian Granillo, Governor of the Ysleta del Sur Pueblo Indian Tribe,
also known as the Tigua Indian Community, dated August 12, 1993, filed
on August 18, 1993, in Volume 195, Page 385, of the Deed Records of
Hudspeth County, Texas.

8. Plaintiff seeks to QUIET TITLE to improve property, because
DEFENDANT refuses to sell additional title insurance. Plaintiff can't
build on the land without risking his entire investment.

9. Plaintiff seeks TRIPLE DAMAGES for DECEPITVE TRADE PRATICES due to
the intentional failure of the Defendant to produce an ABSTRACT of the
PROPERTY so the PLANTIFF CAN QUIET TITLE.

10. Plaintiff is owed the amount of the title contract, or an
ABSTRACT, so the Plaintiff can quiet title.

11. Plaintiff seeks unspecified compensatory and punitive damages,
filing fees, and costs of service.

12. Plaintiff seeks a bench trial, and all other relief this court
deems just or necessary.








Marcus Wayne Roberts
PRO SE
PO BOX 961029
El Paso, Texas 79996

915-988-2530
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Old March 31st 10, 02:03 AM posted to rec.games.chess.politics
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First recorded activity by ChessBanter: Jun 2009
Posts: 406
Default draft of complaint

State of Texas
Hudspeth County 205th District Court


Marcus Wayne Roberts
Plaintiff.

v. Case number

Steward Title Guaranty, Co., A Texas Corporation
Defendant.

COMPLAINT


PARTIES

1. Marcus Wayne Roberts,
Plaintiff,
PO BOX 961029
El Paso, Texas 79996

2. Steward Title Guaranty Co., A Texas Corporation,
1980 POST OAK BLVD STE 800
HOUSTON, TX 770563826

VENUE

3. This contract concerns plaintiff's homestead, located in Hudspeth
County, Texas.

JURISDICTION

4. Claims for deceptive trade practices could exceed 100,000 dollars.
District Court is appropriate.

LACK OF GOOD AND INDEFEASIBLE TITLE

5. This is an action of breach of contract, due to a certain title
policy O-5951-000004116 issued by the Defendant in September of 2009.
Defendants have refused to arbitrate, per clause 14 of the contract.

6. Defendant has insured Plaintiff in the amount of 30,000 dollars
GOOD AND INDEFEASIBLE TITLE, per the title contract attached to this
complaint.

7. "GOOD AND INDEFEASIBLE TITLE" never been legally defined, according
to TEXAS Real Estate Law 10e by Charles J. Jacobus, page 288.

8. Plaintiff is unable to build his dream home one of his three lots
due to a marketability error noted by the Defendant in schedule "B"
item "d" if his title policy:

Claims by the Tigua Indian Tribe of the Ysleta del Sur Pueblo, as
evidenced by that certain Affidavit concerning filing of Notice of
Claim to the Ysleta Grant and Aboriginal Title Areas, executed by
Julian Granillo, Governor of the Ysleta del Sur Pueblo Indian Tribe,
also known as the Tigua Indian Community, dated August 12, 1993, filed
on August 18, 1993, in Volume 195, Page 385, of the Deed Records of
Hudspeth County, Texas.

8. Plaintiff seeks to QUIET TITLE to improve property, because
DEFENDANT refuses to sell additional title insurance. Plaintiff can't
build on the land without risking his entire investment.

9. Plaintiff seeks TRIPLE DAMAGES for DECEPITVE TRADE PRATICES (90,000
dollars) due to the intentional failure of the Defendant to produce an
ABSTRACT of the PROPERTY so the PLANTIFF CAN QUIET TITLE.

10. Plaintiff is owed the amount of the title contract, or an
ABSTRACT, so the Plaintiff can quiet title.

11. Plaintiff seeks unspecified compensatory and punitive damages,
filing fees, and costs of service, which could exceed 100,000 dollars.

12. Plaintiff seeks a bench trial, and all other relief this court
deems just or necessary.


Marcus Wayne Roberts
PRO SE
PO BOX 961029
El Paso, Texas 79996

915-988-2530


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Old March 31st 10, 04:01 AM posted to rec.games.chess.politics
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First recorded activity by ChessBanter: Oct 2009
Posts: 112
Default draft of complaint

On Mar 30, 8:38*pm, NONE wrote:
This isn't NSA, this is greed!


Obviously.

What's amazing is that you actually believe anyone gives a ****.

If you didn't have the mental capacity of a 6-month old Turkish deaf-
mute and the personality of a frozen dog**** snowball, you might
actually be taken seriously. However, Marcus, since you've proven
that you're completely bat-**** crazy, nobody listens to you.

Tell me, when are you going to sink low enough in your psychosis to
finally take a step back, take a breath, and realize that maybe it's
NOT everybody else who's ****ed up and it's just.....YOU?

In the meantime, get some professional help. And some prescription
medication.

Lots.

And take them.

All.

Now.
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