IN THE THREE HUNDRED AND EIGHTY JUDICIAL
COURT IN AND
FOR COLLIN COUNTY IN THE STATE OF TEXAS
TERESA LYNN SCORDO
FROM JUDGEMENT AND
In The Interest of the Children
RICHARD MICHAEL, ASHLEY )
(JURY TRIAL DEMANDED)
LYNN, VINCENT LEO )
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
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 ___________.
11. (#1) Plaintiff, TERESA LYNN SCORDO has been a resident of Collin County since
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.
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
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.
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.
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.
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
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
seeks relief based upon;.
(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
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.
and brought in bad faith;
(2) groundless and brought for the purpose of
(3) groundless and interposed for any improper
purpose, such as to cause unnecessary delay or needless increase
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.
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
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
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
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
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
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
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
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
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
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