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HowTERESA SCORDO & her kids SURVIVED COLLIN COUNTY CORRUPTION

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Judge CHARLES SANDOVAL IS A JUDGE = CROOK
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DATES AND SUMMARY OF CASE:  Teresa Scordo

 

04/20/04 TS informed of child abuse by Richard Scordo FROM their 12 yr. old daughter whom cries & tells the stories to the mother Teresa Scordo. TS then call’s CPS to file report about abuse RE: 7 year old Vincent. (Based on TS being abused by RS during marriage) •

05/08/04 TS confers with an ATTORNEY @ Law to file motion ‘Provoking or MODIFICATION - RS Parental Rights’. (Kenneth Hartless)

 05/09/04 TS Questions RS. RE: 8yr.old physically abused by dog leash. (RS admits) TS informs RS of her intentions to file above said motion & her intentions on retrieving back child support due as WELL as file for an increase and move kids to OKLAHOMA. • •  

05/13/04 TS contacts PPD (Police DEPT) & demands Officer Clark to return TS’s property, removed by RS based on Officers approval while TS was not at her residence. (THE BEGINNING OF HELL) • 

 05/13/04 (SAME DAY BUT IN THE EVENING) CPS TELLS Teresa L. Scordo they conducted interviews with R. Scordo and kids then at 7:00pm & asked Teresa L. Scordo to go to the CPS office so they could interview and talk to her. TS arrived to be informed of false allegations made by RS & (supposedly) her kids pertaining to her abusing her children and having several guns in her home and trying to kill her kids and ex-husband. (Later proven was the fact that the kids were not spoken to by CPS’ caseworker nor EVER ALLEDGE they were abused by their mother. CPS’ case worker never even physically examined any of the kids. •

 05/13/04 (7:30pm) Child Protective Service INFORMS & initiates a 30 day investigation based on the alleged mental instability & physical abuse on 15yr/13yr/8yr old children, against TS – NOT RICK SCORDO, as well as their intentions to investigate physical abuse by RS. (TS signs the 30 day agreement & begins the process they recommended & FULLY ABIDES with out hesitation thinking ‘THE TRUTH WOULD PREVAIL’) •

05/24/04 TS receives the mental exam per CPS & their appointed Physician. Report made/given copies to TS the same day – clearly state nothing more than separation anxiety & physician makes no further recommendation for treatment & or need of any MEDICATION & explains her feelings are normal based on situation. HOWEVER HE STATED ‘You better just kiss THEIR ASSESS – CPS’ …. 06/10/04 TS Request A meeting with CPS caseworker Taheerah Flores ( CPS NEVER REQUESTED ANY INTERVIEWS WITH TS OR HOME VISITS WITH EITHER PARENT TS OR RS) based on the fact the 30 days were ending & CPS informs TS that there were no findings regarding her abusing children & would be receiving a letter stating that by mail. (TS AUDIO TAPES MEETING) 06/14/04 Jassen Alexander is accompanied by McKinney PD at 10am & brings the children back to their residence with mother. RS brings 8 year old back to mother

06/16/04 (originally would not allow him to leave RS residence) • 06/17/04 Children 15/13yr old DEMAND to & indeed does file papers at the court house RE: Preference of Parent & desire to maintain in Mothers care, then they requested to speak to Judge on

July 7, 2004. Teresa L. Scordo told by kids that they never met with anyone from CPS AND didn’t even know who Taheerah Flores was and neither CPS nor anyone else ever visited Shelly Chicks home where they had been residing for 30 days.

06/17/04 3pm- Teresa L. Scordo FURIOUS AFTER finding out that CPS and Program Director and Kathy Stamm had lied because the kids never spoke to CPS – TS calls and gripes out Program Director Katy Gerber RE: There was never any type of investigation involving her kids/her/ ex-spouse etc. 30 minutes later cps (LISA) arrives at front door: DEMANDING KIDS AND MOTHER GO TO CPS OFFICE FOR INTERVIEW. TS REFUSES VIA TELEPHONE CALL: IN THEIR paperwork it states she was doing a welfare check however she saw the kids because they answered the door while TS was on phone call with Katy Gerber.

06/18/04 CPS REMOVES KIDS WITH A WRIT OF ATTACHMNET AND PLACES IN FOSTER CARE: ORDERS READ: MOTHER WAS THREATENING KIDS AND WAS A DANGER TO THEM. (IN COURT STATED THAT THEY WERE REFUSED A WELFARE CHECK AND WAS REASON THEY REMOVED KIDS)

06/20/04 CPS Files the motion to ‘Modify Parent-Child relationship’. (Based solely on unfounded allegations by RS) SUNDAY JUNE 20, 2004 Teresa L. Scordo HIRES ATTORNEY Ryan Nordhaus (last minute-no research) • 06/22/04 TS voluntarily has YET another Mental Exam/Session conducted by: Gail Tate a licensed counsel whom works in Collin County Courts & conducts home studies & evaluations for the courts. (Whom waited outside courtroom for 4 hours on

June 23, 2004 yet was never heard) • 06/23/04 Temporary hearing RE: CPS motion listed above granted & continuance date set. Judge rules ‘Best Interest of Children’ to be with RS however no evidence was presented to warrant this ruling but clearly lacking of information. • CPS was involved for 45 days minimum, based upon no evidence or slight indication. They NEVER interviewed the kids during the 30 days.

ONCE THEY DID CONDUCT INTERVIEW THE STATEMENTS FROM KIDS WERE NEVER COMMENTED ON… Therefore my children were moved from their home to father’s home & a foster home 4 times up this date. (WHY & HOW) • JUNE 30, 2004 CPS - Non-Suit filed & Granted, after presented to an alternate Judge & based upon lack of findings RE: The allegations of abuse by TS. Judge heard & granted motion on June 30, 2004 July 7, 2004 9AM = REVIEW HEARING SET WITH JUDGE SANDOVAL = REVIEW OF CPS’S MOTION TO MODIFY PARENT – CHILD RELATIONSHIP July 21, 2004 T.Scordo still has not received any copies of any orders that were made by the Judge on July 7, 2004 nor has she been contacted by Margaret Turner (FRIEND OF ATTORNEY AD-LITEM ANGELA IVORY & CPS CASE WORKER) after 7 calls requesting to approve and or be in agreeance to the TPO that were outlined by Judge Sandoval to be signed nor has/was her former attorney in receipt of any, until this date or prior to MOTION granted for his withdraw on July 17, 2004. Angela Ivory the appointed Children’s attorney for the 2nd time whom still hasn’t spoken to the kids but has an URGENCY factor due to the kids schedule to return to school on AUGUST 4, 2004!

TS had made a total of 6 calls to Angela Ivory & left messages & a total of 7 calls to Ms. Turner RS’s attorney, TS still relentlessly continued to even call the District Clerk office 5 times (spoke to Angela & Lisa to be told they don’t have the file or copy of docket it was in another place, for this case & the above listed attorneys have yet to contact Teresa Scordo.

JULY 22, 2004 (TS finally gets some information after weeks of calls & visit to the Court House) • MINDI JOHNS WITH THE DISTRICT CLERKS OFFICE SPOKE TO TERESA SCORDO again on July 22, 2004, after TS had waited at the courthouse for 2 hours & Ms. Johns advised TS that she would follow up on TS’s concerns and need of copies/review/urgency-kids school starting ETC! Based on Ms. Johns DO-DILLIGENCE to follow through in an attempt to set a hearing for the ‘Motion for the Judge to Confer with the kids! Ms. Johns called TS & the date was set on July 23, 2004 for the hearing to be held on July 30, 2004 @ 9am.

CASE NOT HEARD BECAUSE EX-SPOUSES ATTORNEY STATED SHE NEVER GOT THE FED-EX (WHICH SHOWS WAS SIGNED BY HER OFFICE – SHE TOTALLY LIED) • JULY 30, 2004- BEGINNING TO THE END CASE SET FOR TRIAL ON AUGUST 30, 2004 – YET CPS SEND TERESA A NEW LETTER THIS TIME AFTER THEY WERE OUT. STATING SHE DID ABUSE HER KIDS AND NEEDED TO SIT DOWN & TELL THEM ABOUT IT. (CAN SEND A COPY IF YOU WANT IT) • JULY 26, 2004-

TS speaks to Layla from Angela Ivory’s office regarding a possible appointment to be scheduled prior to the hearing set for upcoming Friday. (However appointment is still not set or confirmed but LAYLA is attempting to schedule meeting thru Ms. Turner ‘Carrigan’ (attorney for the father). (LAYLA NO LONGER WITH FIRM AFTER Teresa L. Scordo DROPS OFF COPY OF TAPE) Father refuses kids appointment with attorney and then TS drops off tape, then TS finds out Layla is NO LONGER EMPLOYEED THERE AT ANGELA IVORYS OFFICE.

1) On July 30, 2004 – My sister Teresa L. Scordo made a very bad judgment call that has ultimately changed our entire family’s life not even including the HELL her kids are living in now.

2) Judge Sandoval spoke to Teresa L. Scordo privately in the court room. Angela Ivory (attorney ad-item) was also present for some of the conversation.

3) Judge Sandoval told Teresa don’t worry about everything I know what’s going on he will probably be tired of your kids by the time the trial starts in August on the 30th.

4) He demanded Angela Ivory to give my sister legal counsel for about an hour (her ex-boyfriend) was there to witness this luckily. (James Woodard)

5) He told Angela that after she counseled my sister to go back to the chambers so he could talk to her. (Lasted about 40 minutes or so)

6) Then Angela told Teresa what the Judge said and assured her that the Judge realizes that her ex is just playing games. She told her a lot of things he said but most importantly she quoted ‘just make sure that you (Teresa) have ample witnesses from the school etc to testify since the father never played the father role in his kid’s life and didn’t know any teacher’s kid’s friends etc.

7) She also told my sister that “This is your fucking fault because you have tried to force the dad to see the kids”. She the attorney was wrong in any divorce it says parents must enforce the visitations- however my sister always felt like the kids needed both parents and never SPOKE a negative word about their dad to or around them. My sister is extremely witty and an outstanding public speaker amongst other things but she does have her faults=ignorance. She didn’t hire an attorney for the trial because she knew that although her ex had accused her of physically abusing her kids and that he claimed they lived with him for 6 months & after all even the JUDGE acknowledged that personally to her and she knew there were no WITNESSESS that could be honest and testify against her. WITNESSESS WHOM DID: CPS Katy Gerber, LISA HOLDRIDGE = spouse OF Rick Scordo’s computer wizard friend whom lied then TS same day subpoenas her husband because she figured he wouldn’t lie. HE DODGED THE SUPEONA (LISA HOLDRIDGE whom TS only spoke to maybe 3 times in 4 years)

8) The motion for the Judge to confer with the kids 15/13/8 had been filed since June 22, 2004. (HE REFUSED TO SPEAK TO THEM

9) Angela the ad-item met with them one time for 15 minutes a piece all 3 kids. (during a 4 month time frame)

10) My sister had plenty of witnesses ready to go and all the audio tapes (29) in total to prove impeachment/perjury/harassment by his attorney Ms. Turner & tapes of the kid’s new nanny expressing fear of Rick. On 1 of the tapes he EVEN tells her, if you don’t quit talking to the CPS people I will have my rights taken away & never be able to see the kids again. (the tapes were never played in court-even though my sister told the judge she had them) He also threatened to kill our mother on one of the tapes- she told the Judge that as well. He didn’t have time-one day during trial he stated I know you want me to have my lunch right?

11) Henry Mosler a school official was offended by his conduct in the court room. Teresa asked him to state his current position and any other special levels of education etc. =because he was also a foster parent. The JUDGE said ‘I don’t care if he has a PHD! Then he cut off her questioning fully aware that since the attorney for her ex had called the school (they tampered with 4 of her witnesses which she made the judge aware of that as well) he couldn’t come back the last day of trial.

12) My sister attempted to question Rick on exactly how SHE ever verbally/physically abused her kids – then he said she didn’t. Then the judge said NO-ONE has accused you of that. (Totally incorrect, that is exactly how and what he stated on June 23, 2004 & July 7, 2004) under oath in front of Judge Sandoval!)

13) My sister also gave the Judge a sworn affidavit from her former attorneys offices regarding Ms. Turner claiming she was my sister’s attorney in seek of information. (he didn’t seem to care)

14) The night before the last day of the trial her 15 year old son and daughter told her that their dad said she was a prostitute and was severely sexually abused as a child and a lot of other things. Her son missed 2 days of school because of these lies.

15) The Judge knew about it because he allowed the hearsay’ pieces of papers with her picture on it from a computer to be admitted into evidence against her. (How?) After that she questioned Rick’s knowledge regarding building websites and stuff because she paid for his computer school. (he didn’t work for over 1 year)

16) Ultimately on September 3, 2004 my sister addressed the Judge and court stating that she was not going to be able to call her witnesses because of some things conveyed to her the night before by her children & asked for leniency. (oppose to him reconvening on Monday he let her drown) 17) She got it alright- he took away her rights period! The docket sheet didn’t reflect the orders written up by Ms. Turner.

    CONTINUED IN DOCUMENTS

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SCORDO SUES THE COURT
 

IN THE THREE HUNDRED AND EIGHTY JUDICIAL DISTRICT   

               COURT IN AND FOR COLLIN COUNTY IN THE STATE OF TEXAS

 

                         _________________________________________

 

TERESA LYNN SCORDO                                    )                COMPLAINT FOR RELIEF

                              (Plaintiff)                              )                FROM JUDGEMENT AND

In The Interest of the Children                           )                FOR DAMAGES

RICHARD MICHAEL, ASHLEY                 )                (JURY TRIAL DEMANDED)

LYNN, VINCENT LEO                                     )               

                                                                               )                CASE# 380-51276-01

             VS                                                                                  _________________

                                                                                                      PRESIDING JUDGE

RICHARD LEO SCORDO

ANGELA IVORY

MARGARET CARRIGAN’ TURNER

                             (DEFENDANTS)

________________________________________________________________________________

 

             Plaintiff represented during the Modification Trial as Pro Se, hereby submits this Complaint and supporting Memorandum and alleges and complains as follows:

 

NATURE OF ACTION

 

1. This action is an independent action to set aside a judgment and declare it a nullity due to fraud upon the Court, and to assess actual and punitive damages against the Defendants due to various

intentional and negligent torts that arose directly from the defendants fraudulent accusations which were unfounded and misconduct, as well as said attorney’s misconduct. All elements of the cause of this action arose out of the filing and hearings and actual trial of the ‘Parent and Child Relationship Modification’ originally filed by The Department of Family and Child Protective Services, then further pursued by defendant Richard Leo Scordo and ruled and made a final judgment by Judge Charles Sandoval.

 

This suit is brought before this Court as an independent action due to numerous frauds and misconduct committed by Defendants and Judge Charles Sandoval presiding in the 380th Judicial District of Collin County Texas. Thus acknowledging the Judge’s reckless disregard of any and all laws set out by the Texas Rules of Civil Procedure, Collin County Local Rules, Eastern District Rules, and Texas Supreme Court Rules as well as the Texas Judicial Conduct Standards set forth.

 

           Plaintiff brings this action in an attempt and an effort to protect and preserve the legitimacy of this Court and the Orders of this Court by rectifying any and all fraudulent activities perpetrated on and by the courts officers along with seeking all parties are held to the fullest extent in the penalty phase. Plaintiff prays that this suit will be an example and ultimately prevent any further empowerment of similar destruction to citizens and innocent children that fall into the hands of JUDICIAL FRAUD AND MISCONDUCT due to fraudulent activities in our court system which causes most parents to give up in similar cases, based upon the acceptance and advice of TEXAS ATTORNEYS and POWER of the judicial system as it stands today.

 

JURISDICTION AND VENUE

 

1. Plaintiff has followed the proper procedure regarding filing an extensive formal complaint with the Texas Judicial Commission on Misconduct; regarding Judge Charles Sandoval.

 

2. The behavior and actions complained of occurred in Collin County Texas.

 

3. This Court has exclusive jurisdiction of and over this case.

 

4. This Court has original jurisdiction to hear independent actions attacking the validity of a previous judgment due to fraud upon the court pursuant to _________.

 

5. This Court has original jurisdiction to hear tort claims due to intentional and negligent conduct.

 

6. The parties in this matter are all residents of and or do business in Collin County Texas.

 

7. All parties are of sufficient age and legal status to sue or be sued under the laws of the State of Texas.

 

8. Venue is proper pursuant to _________________.

 

9. Relief due to injuries to a minor child is proper under_________.

 

10. Relief due to injuries is proper under ___________.

 

PARTIES

 

11. (#1) Plaintiff, TERESA LYNN SCORDO has been a resident of Collin County since 1992.

 

She was denied any and all proper judicial process in the matter in question, and suffered actual and general damages.

Therefore she has the right and legal standing to bring this suit to action.

 

DEFENDANTS

12. (#1) Defendant, RICHARD LEO SCORDO has been a resident of Collin County Texas since 1992. He committed frauds upon the court personally, and he is a party who benefited and benefits prospectively from the fraud upon the Court and is averse to any ruling for Plaintiff in this matter and is therefore a proper defendant in this action.

 

13. (#2)  Defendant, ANGELA IVORY conducts business in Collin County Texas and is named a party due to the fact that Defendant  was acting as a representative of the court when appointed by Charles Sandoval as the Attorney Ad-Litem for the children in this suit as listed above. As her duties are set out by the Texas Rules of Civil Procedure her misconduct and negligence and intent can be imputed because of the lack of her duties in this suit she is a party to this suit and named a defendant in this matter.

 

14. (#3) Defendant, Margaret Carrigan Turner conducts business in the Dallas County District as well as the Collin County District and is named a party due to her fraud by misrepresentation as an attorney for Plaintiff to said law firm Hartless & Hargrove as well as tampering with witnesses amongst other issues to be set out below and is named a defendant in this matter. 

 

GENERAL & SUBSTANTIAL ALLEGATIONS

 

15. During all times, Defendant Angela Ivory was acting as a representative of the Court

 

16. The claims made in this action have never been raised in any prior legal proceeding between the instant parties.

 

17. On or about June 18, 2004, Defendants filed a Verified Complaint for MODIFICATION OF THE PARENT CHILD RELATIONSHIP in the 380TH DISTRICT Court.

Case #: 380-51276-01

 

18. Plaintiff properly responded to the SUIT filed as the counter respondent within the time limit AND made a plea of denial.

 

19. The hearing to determine temporary Orders was held on June 23, 2004. Plaintiff was granted extended visitations even after CPS caseworker admitted she did not interview the children until 2 days prior to this hearing which was on June 21, 2004. In which she stated the children were never abused nor neglected by the plaintiff and she (CPS) never preformed a physical exam on the 7 year old, Vincent Leo which was beaten with a dog leash by defendant RICHARD LEO SCORDO and ultimately underwent surgery for a hernia.

 

20. Defendant accused the Plaintiff of abusing the children during the hearing, yet during the trial denied there were ever any concerns of abuse.

 

21. Defendant Turner fraudulently represented the actual temporary and final Orders of Judge Sandoval in her draft, and subjected Plaintiff to significant additional restraint that was not intended by Judge Shumate at that time and ultimately caused harassment by both the defendant Scordo and defendant Turner.

A) Ex-Parte Communications with Respondent that ultimately led her to Trial without counsel. Judge C. Sandoval spoke to the Plaintiff in the courtroom on July 30, 2004 regarding the case and the defendant Scordo. C. Sandoval not only gave plaintiff legal advice but he also quoted’ don’t be concerned with CPS I knew they were lying at the 1st hearing. Then walks Angela Ivory (ad-litem) she told the Judge defendant Ms. Turner was out of town and unable to make the hearing “Motion to Confer with the children”, which had been filed since June 22, 2004. We all conversed for about 25 minutes about my ex-spouse the defendant and the desire for the 13/15yr old to speak with the judge. All of which took place in the courtroom then he directed the Angela to give me legal advice for about an hour then return to him afterwards and he would tell her how to advise me.  There were witnesses at the courthouse and in the courtroom that morning as well as the 3 children whom the Judge had the attorney secure in a locked room with toys and such across from his court room on the 4th floor.

 

B) Obviously I am not an attorney, nor was I familiar with the law period, the Judge and the attorney (ad-litem) Angela Ivory clearly disregarded the law and led myself and children along with witnesses present to firmly believe and TRUST that there was no need for me to hire another attorney, because the Judge straight out told me ‘the plaintiff’ not to worry he knew the truth.(that my ex-husband and CPS were lying about me abusing my children).The attorney clearly knew this was against the law and considered misconduct by TRCP, yet she spent an hour with me and a friend then about 20-30 minutes with the judge prior to returning to assure the plaintiff (myself) that I just needed to make sure I had some witnesses to attest to the fact that I had never abused my children. Upon leaving the courthouse the children were elated that the judge had in fact told me what he did, as these are teenagers life’s we are dealing with.

 

C)     'Plaintiff' seeks relief based upon;
(3)  'Groundless' means:                                                     
(A)  no basis in fact; or                                                  
(B)  not warranted by existing law or a good faith
argument for the extension, modification, or reversal of existing
law.
 

 

22. Defendant had an obligation to notify the plaintiff of any health issues or concerns yet the 3 children had various issues arise in which he failed to notify plaintiff which was a direct CONTEMPT with the court.

A) Richard M. suffered from a broken hand which required surgery.

B) Vincent Leo suffered from a hernia which required surgery.

C) Both boys were involved in an automobile accident with defendant’s live-in girlfriend.

D) Ashley & Richard M both were treated for spider bites which required the draining of the poisonous infection.

E) Vincent L. 8yr.old was suspended from school 4 times during a 3 week time frame.

F)  Vincent L. was left unattended for several hours by defendant Scordo during the days in which Vincent was suspended from school. The neighbor notified the plaintiff of the above concerns.

G) Michelle Howe the sitter hired by defendant Scordo testified to the fact that at times she and the children were locked out of the residence.

H) She also testified to the fact that the children’s health was being neglected by defendant Scordo.

I)  She also testified that there was no telephone she had access to in the defendants home at times in case of an emergency, which caused her great concern.

J) She also testified to the fact that defendant Scordo personally verbally abused her at times in front of the children. (she was terminated immediately following the trial) Causing yet more stress and instability to the children by being left in harms way.

    

23. Judge C. Sandoval scolded the witness regarding her contacting me with her concerns when she worked for the defendant Scordo. She explained she was doing what was in the best interest of the children.

 

24. Trial was finally held in September 1-3rd 2004 although it was scheduled for August 30th,

since July 7, 2004.

25. Prior to the trial on August 30, 2004  Judge Sandoval denied Plaintiff’s Motion for and or Discovery which was filed by plaintiff on July 15, 2004, although defendant Turner failed to seek a protective order. Prior to trial Judge Sandoval also denied the plaintiff 15 minutes as requested to see any discovery and or witness list entirely. Plaintiff submitted her discovery and witness list accordingly with the local rules.

 

26.  Judge made an irrevocable error when he named Teresa L. Scordo as a mere Possessory Conservator without the findings of facts of law in pursuant to Texas Rules of Civil Procedure and Guidelines 153.251 through 153.258, her legal remedy of request filed on September 20, 2004 and called upon for statement in open court by Attorney Lisa Hernandez, yet still remains to be acknowledged by said court.

 

27. Neither Judge Sandoval nor Defendants asserted that Plaintiff was barred by procedural

issues or rulings, however plaintiff supplied court with documents from the children’s school that clearly stated that the defendant lied to the school officials on or about August 11, 2004 when he said plaintiff was in fact barred.

 

28. No allegation was made by Defendants or Judge Sandoval that Plaintiff’s claims were in bad

Faith or lacked merit, yet were never allowed in questioning as a PRO-SE.

 

29. Plaintiff asks Judge for time; Last day of trial time for Teresa L. Scordo to present case yet she finds herself at the mercy of 2 sick children (throwing up non-stop) at home from school based on stories bestowed upon them by their father the night before (ATTEMPT OF PARENT ALIENATION SYNDROME) – leaving Teresa L. Scordo to ask the court to reconvene or acknowledge her inability to present HER case based on the extenuating circumstances. –Judge speaks ---Court – Must go ON!

 

30. Judge Sandoval stated, prior to evidence or testimony being presented at trial that he did not believe that joint physical custody was in the best interests of children, which totally disregards the law that allows for such a determination and showed his personal bias toward Plaintiff’s lawful

claims for relief.

 

               A) This was also in violation of Cannon 3(E) (1) and Cannon 3(B) (5) of the TEXAS

Rules of Judicial Procedures and Administration.

 

31. Subsequent to Judge Beecham’s refusal to rule on the merits of Plaintiff’s Motion, testimony and

evidence was presented where Defendant Williams fraudulently represented to the Court that she

and Plaintiff argued about whether or not the child should be home schooled.

 

32. On cross examination, Defendant Scordo admitted not only that she and Plaintiff had never

actually had an argument on that matter, but that she and Plaintiff had never actually had any

fights during their entire marriage.

 

33. Defendants filed the facts and findings and conclusions of Law late, after plaintiff filed a past due notice in said court.

 

34. Subsequent to the trial, Proposed Findings of Fact and Conclusions of Law were not submitted as the plaintiff filed for discovery including under rule 190 level 2.

 

35. Judge Sandoval found entirely for Defendant Scordo and Turner on all claims.

 

36. Judge Sandoval committed error when he failed to allow the plaintiff/mother to be able to continue their family tradition of having lunch with her children one day a week, each child every week since kindergarten. 

 

37.  Judge Sandoval did not comment on any claims made by Plaintiff,

instead he ignored them completely, even where there were no opposing claims by Defendants.

 

38. Judge Sandoval used and allowed Defendant Scordo’s perjured testimony in order to show cause to deny Plaintiff her right to both physical and legal custody including NO COMMUNICATION with any children. Plaintiff informed Judge that she had several audio tapes to prove perjury and impeachment, yet it was never allowed.

 

39. Judge Sandoval found that it was not necessary to confer with the children and didn’t allow the 15 yr. old or 13 yr. old to testify after being sworn in on July 7, 2004 although they desperately wanted to fight for their life as well and speak to the Judge since their attorney would not speak to them. That in itself is an absolute injustice to all mankind let alone children.   

 

40. Defendant Scordo personally told plaintiff Teresa L. Scordo and children that she could take the children in July to Oklahoma to visit their family as they did every summer (taped on audio) yet the harassment started 2 days later when Defendant Turner started calling plaintiff threatening to file a Writ of attachment and remove children from their uncles home in Oklahoma. Plaintiff then filed a motion for clarification of temporary orders, Bill Powell (bailiff) set it for the same day as the trial August 30, 2004 and of course it went unheard and the harassment remained.  

 

41. On June 23, 2004 through attorney Allison Dietrich for CPS a settlement was offered to the plaintiff and she once again refused believing in the system and that the Truth would prevail.

 

42. Defendant Angela Ivory failed to adhere with the rules of TRCP, as well as failed 3 children when she refused calls from children and only spoke to the children 15 minutes each on July 29, 2004 in a 4- month time frame. Yet she informed another attorney that she believed the plaintiff/mother was encouraging the children to call her (once incident involving father not getting antibiotics for a spider bite) & that only the older children wanted to be with their mother-discussion in the chambers of 380th on August 30, 2004. However that was after the plaintiff confronted the defendant regarding only spending 15 minutes with the children and not realizing the living conditions with defendant Scordo.

 

43. Defendants had a duty to Plaintiff to inform her of their discovery and or a witness list according to the local rules set by Judge Sandoval himself.

 

44. Defendant Turner did not file any certificate of service that shows she mailed any documents in case to plaintiff. However she committed fraud when she misrepresented material facts to

the Court about her call to law firm Hartless & Hargrove.

 

45. Prior to trial, on June 23, 2004 Plaintiff’s attorney was addressed by defendant Scordo’s attorney and offered to settle if the plaintiff would agree to give him the 8 year old. The plaintiff refused any settlement due to the abuse she was aware of via the hernia he caused by the beatings and the final blow with the dog leash. Furthermore this proves the innocence of the plaintiff regarding any abuse alleged in hearings yet dropped during trial.

 

 

46. The Defendants and Judge attacked and allowed mental and emotional abuse on plaintiff during trial regarding her education level and earning potential. Meanwhile defendant Scordo knew plaintiff had supported the entire family during their marriage due to his lack of job and her earning means.

 

47. Subsequently Defendants represented to the Court that the plaintiff could not earn over 100K a year based upon the fact she had not graduated from high school or college. (IRREVELANT) and plaintiff very well had made that amount with her previous companies.

 

48.

 

 

49. This fraud was not only upon the court, but also upon Plaintiff as well as the 3 innocent children, as she was assured that an agreement of mediation would be made when it was set by the court on July 7, 2004 yet totally disregarded when a mediator was contacted by the Plaintiff. She unfortunately in ignorance of the law relied on that fact, and was somewhat at rest believing that the inevitability of trial would be dismissed or a mediation would be met or at the least the truth would be heard-not hearsay by a disgruntled and in contempt ex-spouse Defendant Scordo.

 

50. Any reasonable person would have known that after the difficulty Plaintiff had in keeping her

emotions in check during the July 30, 2004 hearing (EX-PARTE COMMUNICATIONS), a mother who loved and cared so much about her children and endured severe emotional distress at the loss of her parental rights and obligations of legal custody. Yet the plaintiff researched every single day in order to fight for her legal rights. The fraud committed in effort to effectuate that goal offends against the generally accepted standards of decency and morality.

           A) The mother who gave up any and all tangible assets including; her home, car, home furnishings and more in order to dedicate her life day to day in a FIGHT for her children.

 

51. Any reasonable person would know that committing fraud in order to infringe on a person’s

fundamental parental rights would cause severe emotional distress and it offends against the

generally accepted standards of decency and morality.

 

52. Any reasonable person would know that committing fraud in order to separate a fit parent from

children would cause the children severe emotional distress and it offends against the generally

accepted standards of decency and morality.

 

53. Plaintiff has suffered actual damages in the form of attorney fees in an amount of $7,000.00 as a

direct result of Defendant’s illegal actions and bad faith representations.

 

54. Plaintiff has suffered actual damages in the form of emotional & mental anguish as well as severe anxiety caused by the obvious obstruction of justice in our Court system. 

 

55. Plaintiff has suffered irreparable harm due to the denial of his fundamental right to the care, custody and basic companionship of her 3 children, and her right to fundamental decision making in areas regarding her children.

 

56. Plaintiff has suffered irreparable emotional distress due to the loss of her parental rights to the care, custody, communication (except during supervised visits 8-hours monthly) and companionship of her children because of the frauds, which has caused him situational depression.

 

57. Plaintiff has suffered irreparable harm due to the denial of LEGAL due process she received due to the irrevocable illegal acts of any and all Defendants.

 

58. Plaintiff has prejudgment interest in the losses claimed as she was unlawfully denied her rights and privileges during the process and prior to the unlawful, illegal judgment.

 

59. Plaintiff suffers from a general distrust of any and all of the Court systems based and due to the multitude of frauds and misconduct perpetrated against her and by the attorneys and judges in this suit.

 

60. Plaintiff has suffered general damages in which can never be replaced including but not limited to the denial of being listed as the emergency contact and mother of the children at the school they attended as well as the right to care for their basic health needs, due to the fraud and intentional misconduct of Defendants.

 

61. Plaintiff’s actual and general damages will never be able to be accessed accordinig to the substantial loss of time, emotional distraught, inability to protect her children and the ultimate CRIME the abuse caused upon the children due to this Judgment from fraud and desire to defame and harass.

 

62. All conduct complained of occurred between the dates of June 23, 2004, and continued up to the date this complaint was legally filed.

 

63. All conduct by Defendants shows an obvious pattern of illegal conduct and total disregard for any and all laws set out by the STATE OF TEXAS, in this case alone for a period of 6 months at least, which is a total outrage for any and all abiding legal citizens and must be haulted and proven legally by the court as being intolerable and punishable for any and all parties.

 

 

 

CAUSE OF ACTION

 

64.  'Plaintiff' seeks relief based upon;.
'Groundless' means:                                                     
(A)  no basis in fact;  or                                                  
(B)  not warranted by existing law or a good faith
argument for the extension, modification, or reversal of existing
law. including an action based on intentional
conduct, negligence, strict tort liability, regardless of
the legal theories or statutes on the basis of which recovery is
sought, including libel, slander.

Added by Acts 1987, 70th Leg., 1st C.S., ch. 2, 2.01, eff.
Sept. 2, 1987.

 

(1)  groundless and brought in bad faith;                                    
(2)  groundless and brought for the purpose of
harassment;  or             
(3)  groundless and interposed for any improper
purpose, such as to cause unnecessary delay or needless increase in
the cost of litigation.

4) Malice and Intent to harass and harm and constituiting fraud

Added by Acts 1987, 70th Leg., 1st C.S., ch. 2, 2.01, eff.
Sept. 2, 1987.

65. Plaintiff was denied any possible fair judicial process and an opportunity and right to have her claims, case and witnesses decided up on the merits in the suit of the ‘Modification of the Parent Child Relationship’.

 

66. Defendant ANGELA IVORY committed fraud upon the Court when she fraudulently failed to represent the children in this suit as set out by the TRCP guidelines for an attorney ad-litem.

 

67. Judge Sandoval committed fraud upon the Court by refusing to exercise his judicial duty and rule

on the merits of Plaintiff’s claims due to his prejudice.

 

68. Judge Sandoval committed fraud upon the Court by refusing to exercise his judicial duty and rule

on the merits of Plaintiff’s Motion for Writ of attachment as heard on December 1, 2004, ultimately causing more stress and emotional & mental abuse with no just cause after the proper remedy was filed and verified by witnesses via the plaintiff.

 

69. Judge Sandoval willfully and knowingly committed fraud upon the Court by actual bias as evidenced by his Order granting Defendant Scordo sole physical and sole legal custody after making prejudicial statements about his personal beliefs on custody prior to evidence or testimony being presented during the trial, as well as his reliance on false testimony in order to substantiate his findings regarding custody. (he raised his boys alone)

 

70. Defendants intentionally committed fraud upon the Court by not giving proper notice to Plaintiff

of their intentions of seeking a motion for continuance, no service was served to plaintiff.

 

71. Defendants perpetrated fraud upon the court when they used fraudulent information in order to

entice Judge Sandoval into overturning his competency, regarding his decision that the Parties must converse with a mediator as set out on July 7, 2004.

 

72. Defendants all benefited from any and all frauds they construed and committed and received illegal gain as a result and personal empowerment along with financial gains.

 

73. Defendant MS. TURNER benefited monetarily from the fraud.

 

74. Defendant Scordo benefited monetarily financially and by harassment due to having FULL rights to custody of the children he shares with Plaintiff enlarged.

                    a) The Children suffered greatly due to this vast change in custody.

 

75. Plaintiff was unlawfully denied her right to a fair, unbiased and proper trial on the merits due to

the gross amount of fraud.

 

76. Defendants intentionally denied Plaintiff due process and equal protection of her fundamental

parental rights by their fraud.

 

77. Defendants intentionally denied Plaintiff her fundamental right to the care, custody, and

companionionship of her minor children by their fraud.

 

78. Defendants intentionally denied Plaintiff general due process by their fraud.

 

79. All complained of conduct of Defendant Angela Ivory and Margaret Carrigan Turner was in violation of the TEXAS Rules of Professional Conduct.

 

80. All conduct of Judge Sandoval was in violation of the TEXAS Code of Judicial Conduct.

 

81. All complained of conduct of Judge Sandoval was in violation of the Utah Rules of Professional

Conduct.

 

82. Judge Sandoval showed reckless disregard of the truth when he refused to allow the OBJECTION OF hearsay by the Defendant Scordo and or attorney.

.

83. Judge Sandoval actions, when viewed together, show that he made his findings in an effort to

intentionally defraud the court.

 

84. Defendants inflicted actual and general damages upon Plaintiff as a result of the intentional fraud

upon the court.

 

85. Defendants inflicted actual and general damages upon Plaintiff as a result of all of the torts

complained of.

 

86. Defendants, by their frauds, misconduct and bad faith, caused the vitiation of the decree, which

makes all attorney fees Plaintiff incurred for nothing. They should be liable to reinstate those

fees so that Plaintiff can begin future litigation on the same footing as before the fraud.

 

87. Defendants are guilty of the tort of abuse of civil due process.

 

88. Defendants are guilty of the torts of negligent misconduct, negligent misrepresentation and/or

negligence.

 

89. Defendants are guilty of the tort of willful misconduct.

 

90. Defendants are guilty of the tort of intentional infliction of emotional distress due to their

outrageous and intolerable conduct.

 

91. Defendants should be held liable to pay actual and general damages as to be determined by a

jury.

 

92. Defendants should be assessed punitive damages as decided by a jury TRIAL.

 

 

 

 

 

 

RELIEF SOUGHT BY BOTH THE PLAINTIFF AND THE CHILDREN

 

Plaintiff is hereby claiming that the general damages alone are in the excess of $1,000,000.00.

 

Plaintiff is hereby claiming on the behalf of her 3 children; RICHARD MICHAEL 15 YEARS OLD, ASHLEY LYNN 13 YEARS OLD, VINCENT LEO 9 YEARS OLD; the damages incurred by the children due to their suffering and mental, PHYSICAL and emotional anguish and abuse is in the excess of $15,000,000.00. Plaintiff prays that any and all relief sought and to be paid to the children be placed in a trust fund until the children are of the age of 18 years old and or that a trustee be appointed by Teresa Lynn Scordo on the children’s behalf.

 

Plaintiff is hereby claiming the damages due to the fraud and defamation of character by the defendants in the excess of $10,000,000.00.  

_____________________________________________________________________

 

 

WHEREFORE, Plaintiff prays for ADDITIONAL relief as follows.

 

1. Each and every one of the following parts of the ‘Modification of Parent Child Relationship’ be set

aside:

a. Child custody, including physical and legal custody,

b. Child support,

c., Permanent Injunction, enjoining, lunch with children, Contact Information for mother on school records, restraining mother from communicating with children, via telephone or any other method. 

d. The Visitation Schedule,

e. Any and all awards for various monies as set out above.

f. Reimbursement for all mental exams and or other testing needed in this case.

g. Reimbursement of any and all Legal Fee’s including attorneys and or any copies, faxes, telephone calls etc.

 

 

3. Defendants should be required to pay all attorney fees and/or costs of court

Plaintiff may incur in this matter.

 

4. Defendants should be required to pay all reasonable attorney fees and/or costs of court

Plaintiff incurs due to the necessity to have the Modification properly retried.

 

5. Intent should be imputed to Defendant’s Margaret Carrigan Turner and Angela Ivory and or any said law firm in which they practice.

6. Defendants should be required to pay actual, general and punitive damages, including the damages as set out above regarding the 3 minor children RICHARD MICHAEL, ASHLEY LYNN, VINCENT LEO SCORDO as to be determined by jury, minus amount of damages attributable to the fraud of the immune party Judge Charles Sandoval.

 

7. Defendants should be assessed punitive damages.

 

8. Any such further relief that may be deemed appropriate under the circumstances.

 

Plaintiff hereby requests trial by jury on all issues in this matter that may be heard by jury, and

requests that the jury determine actual, general and punitive damages pursuant TRCP.

 

 

JUDGE TOTALLY DISREGARDD LAWS WHEN THE MOTION FOR NEW TRIAL WAS FILED IN accordance with TRCP 320 MOTION and ACTION OF COURT THEREON
New trials may be granted and judgment set aside for good cause, on motion or on the court's own motion on such terms as the court shall direct. New trials may be granted when the damages are manifestly too small or too large. When it appears to the court that a new trial should be granted on a point or points that affect only a part of the matters in controversy and that such part is clearly separable without unfairness to the parties, the court may grant a new trial as to that part only, provided that a separate trial on unliquidated damages alone shall not be ordered if liability issues are contested.

 

O) The depth of damages and error by this said court heavily out weigh any and all circumstances and or evidence or proof regarding this case as well as the ability to outline each and every rule or error by Teresa L. Scordo herself. I understand the rules in filing additional information in this case and do intend on providing additional information as the law allows. Therefore I must hope and believe I have included the most damning information only by your own examples and reason to accept Just Cause and cases in this matter. The legal remedies available for this case and its damages thus far, including the filing of a formal and in depth complaint with The Commission of Judicial Misconduct have been filed and done so in a timely manner as necessary.

 

3. Teresa L. Scordo desires to appeal from any and all portions of the Judgment as the majority’s are listed below, yet does not include all available details supporting the facts as stated herein: Including; Movants personal copies of various audio tapes involving pertinent legal members (Licensed by The Texas Bar) outlining The Errors of this said court and its reputation to that of Consistent Errors in which obviously has and remains to prey upon children and women in the court without failure:

 

A) The Mother & child relationship with all 3 children in suit, ultimately leading to only

8- hours of Supervised/Paid visits with children, VIA (Alma Hayes) without any just cause or reason as stated in open court. ERROR BY Court: Ex-Parte Communications with Respondent that ultimately led her to a Trial without counsel. Incident which took place on July 30, 2004 did involve witnesses, Attorney ad-litem Angela Ivory & Family Friend James Woodard, as well as the 3 children present during this Error of the court.

 

B) Total disregard for the children’s voices to be heard and the truth from their mouths or files of affidavit to be acknowledged when in fact Richard M. is 15 years of age and Ashley Lynn is 13 years of age and the children were estranged from the above said biological father whom the court appointed Sole Managing Conservotorship to even after the legal remedy available was also filed ‘Motion to Confer with Children’.

 

C) Named Teresa L. Scordo as a mere Possessory Conservator without the findings of facts of law in pursuant to Texas Rules of Civil Procedure and Guidelines 153.251 through 153.258, her legal remedy of request filed on September 20, 2004 and called upon for statement in open court by Attorney Lisa Hernandez, yet still remains to be acknowledged by said court.

 

 

D) Permanent Injunction binding Teresa L. Scordo from any and all communications with the said children in suit including their family ritual of Lunch each week at School.

 

E) Children are unjustly and believed to be frivolously preyed upon by the court by granting and upholding – READS: Permanent enjoined by Teresa L. Scordo, regarding even being listed as their mother on any and all school contact information and or emergency contact for all three children. Court made it impossible for children to be picked up by mother as outlined in copy of orders.     

 

F) Time for Teresa L. Scordo to present case yet finds herself at the mercy of 2 sick children at home from school based on stories bestowed upon them by their father the night before – leaving Teresa L. Scordo to ask the court to reconvene or acknowledge her inability to present case based on the extenuating circumstances. –Court – Must go ON!

 

G) No Telephone COMMUNICATIONS to or with the only mother in which all 3 children lived their natural life with at any and all times previously without concern or any fact or reason thereto for concern. Children are left to wonder why and how they could ever be ripped out of the only home and parent in which they knew and loved and then ultimately told NO COMMUNICATION WHATSOEVER BY COURT.  

 

H) Obstruction by the said court of any and all laws as set out by Texas and Local as well as the courts own Local Laws/Rules. Attached hereto you will find the list of as well as the facts regarding to say law. Incorrect Court Report as attached hereto.

 

I) Courts disregard of attention being brought to the record, regarding opposing attorney Margaret Carrigan Turner; contacting Teresa L. Scordo’s former attorney (Hartless & Hargrove) and her misrepresentation of whom her client was (stating she was Teresa L. Scordo’s attorney oppose to Richard Scordo) in seek of confidential information. (Affidavit copy attached)

 

J) Not allowing timely served discovery in case filed by Teresa L. Scordo yet allowed the Petitioner and attorney to tamper with witnesses in case which ultimately caused a great injustice to Teresa L. Scordo regarding their absentee. (Letter filed with court regarding proof of tampering as well as testimony thereto in open court by Michelle Howe). 

 

K) The obvious injustice of the court and error in this case still remains to end based on the latest filing of yet another legal remedy Findings of Facts and Conclusion of Law on October 14, 2004 still unanswered by the court.

 

L)  Motion to Sign orders in suit brought by and only after Teresa L. Scordo makes copies of all dockets, filings and then receives order written by opposing parties attorney (then has Legal firm Goldstein & Scopelitte contact opposing attorney disputing) and it clearly does NOT REFLECT the orders and or docket entries made by the court and is manifestly harmful for both the mother and children if signed without the court showing any type of just cause.

 

M) NO COURT REPORTS as ordered – No RESPONSE until November 5, 2004, when Teresa L. Scordo contacted in writing (copy attached) the district clerk on September 8, 2004 the same day she made the copies as listed above. (3 requests formal & 4 via attorney and or telephone)

 

N) Motion for New Trial disregarded and as told to Attorney Lisa Hernandez and Teresa L. Scordo; the court would just wait out the statue of limitations by law, but no new trial.

 

 

UPDATE THE CHILDR3EN WERE REMOVED FROM RICHARD SCORDO’S HOME ON DECEMBER 14, 2005 & ARE LIVING BACK IN THEIR OWN RESIDENCE WITH THEIR MOTHER & THE FINAL ORDERS WERE SIGNED ON JANUARY 13, 2005.

 

THIS ONLY FURTHERMORE MORE PROVES FRAUD UPON THE COURT BY ALL ABOVE STATED PARTIES.

 

 

 

 

 

 

 

 

 

 

VERIFICATION OF COMPLAINT

 

I, TERESA LYNN SCORDO, having been duly sworn, hereby depose and state as follows:

 

1. I am the Plaintiff in this action.

2. I have read the foregoing complaint AND am of competent mind to fully understand the pleading.

3. I have read the allegations in the complaint and they are true and factual to the best of my personal knowledge.

 

 

DATED this _____ day of _______, 2005.

___________________________

TERESA LYNN SCORDO

Plaintiff Pro Se

WWW.TERESASCORDO.COM

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TERESA SCORDO