Case no: ev31c0045876
In the Justice Court Harris County, Texas Precinct 3 Place 1
PLAINTIFF: Carl & Lois Mitten Family Partnership LTD
Vs.
DEFENDANT: Robert and Virginia Pierson
Answer and motion for counter bond
I the defendant Robert Lee Pierson Jr. Do hereby affirm that this written answer and motion for counter bond is true and correct to the best of my knowledge. The defendant further understands that any deliberate failure to state the facts set forth in this answer truthfully and correctly constitutes perjury under the laws of the State of Texas.
Defendant would show, that the plaintiff has engaged in fraud, breach of contract, coercion, threats, retaliation, and harassment regarding both the verbal contract entered into in February and the current written contract entered into in February. And that the Plaintiffs is abusing the legal process of forcible detainer and that this abuse of process is willful and wanton and committed with malice and reckless disregard of the rights and safety of the defendant, and the general public. And that the plaintiff has also attempted to violate, or has violated, the defendant’s constitutional right to not be enslaved, to habitable housing, to a safe working environment, to and to just compensation for their labors. The defendant’s also contend that the Plaintiff’s exhibit A is misleading, and that their exhibit B is an attempted fraud upon the court.
I
Defendant would also show that the plaintiff has also engaged in coercion, threats and harassment against Craig Peeler, (a Sergeant with the Harris County Sheriff’s Office) because plaintiff does not want law enforcement on his property. And that the plaintiff has at least three good reasons for not wanting law enforcement, on his property, and that such purposes are not legitimate, regular, or legal in use of forcible entry and detainer actions. It should be noted that Sergeant Peeler keeps his horse here on this property as per my agreement with Dr. Mitten. It should be further noted that Sergeant Peeler is a member of the Harris County Sheriff’s Office Mounted Patrol with years of equine training and care experience.
1) Defendant would show, that the plaintiff is now engaged in the abuse of an unlawful detainer action for the ulterior motive or purpose of evicting law enforcement from the property, because the owner was forced to provide medical care for an abused and neglected horse by the name of Hurdlin by Sergeant Peeler. This can be verified by both Sergeant Peeler and by Dr. James Hall, DVM who treated this horse.
When the horse named Hurdlin arrived at the farm from a trainer the defendant was told that the horse had two abscesses in his two front feet and was emaciated because he had worms. Defendant was told by plaintiff to put the horse in the back pasture, and give him worming pellets and MSM. Although I am no Equine expert even I knew that the horse was in need of medical attention despite the prognosis I was given by Dr. Mitten.
I brought the horse up to the front pasture when he stopped eating so Dr. Mitten could see for himself how bad the horse’s condition was. When Sergeant Peeler saw him he immediately knew that the horse was in need of medical attention and demanded that the horse be seen by a veterinarian who was qualified to treat founder and/or laminitis, a painful and fatal condition if not treated. Had the horse not been treated he would have died a slow and painful death. Dr. Mitten could have claimed for insurance and or tax purposes that a perfectly healthy horse had died for no apparent reason. Once he was taken to Dr. Hall by Sergeant Peeler and he was diagnosed as having founder, the plaintiff could no longer make this claim. Had Sergeant Peeler not observed and taken this horse to the veterinarian the plaintiff could have taken a substantial tax loss, or if insured, a substantial insurance settlement upon the inevitable slow painful death of this horse.
2) The plaintiff while both far sighted and keen sighted but can have his entire field of vision blocked by a dollar bill and as a result the plaintiff and his agent know as Edger, regularly engage in reckless behaviors that puts both the general public and the horses they own in danger.in fact the defendant will show that the plaintiff put the general public and several horses in danger of serious injury and death for several days so he could attempt to recover repair costs to his fence that were in fact repaired by the defendant for about Twenty (20) dollars after Hurricane Ike.
On or about September 14 the defendant informed the plaintiff Dr. Carl Mitten that an electrical utility pole had knocked down a section of fence on the property located at 7108 Miller Road 2. The hole was in the pasture, South of the house, in the fence running parallel to 7108 Miller Road 2. I also notified Dr. Mitten on the above date that the hole in the fence needed to be repaired immediately. Dr. Mitten then told me that I was not to repair the fence until he could take pictures of it, so that he could get the electric utility to pay for the repairs. Since I was not allowed to repair the fence I propped up the section that had been knocked down against the sections of fence still standing to prevent the horses in the pasture from getting onto Miller Road 2, a two lane road with no shoulder and which has a 45 MPH speed limit.
About 3 days later on or about September 17 a Harris County Deputy Sheriff Christopher Adolph, who patrols the area knocked at my residence at 7108 Miller Road 2. (Deputy Adolph was recently promoted to Sergeant) at this time informed me that he had observed a hole in the fence that a horse could easily escape through and get onto Miller Road 2 and that was why he was at my residence. I informed Deputy Adolph that I was already aware of the hole but had been told by the owner Dr. Carl Mitten not to repair it. I told then Deputy Adolph why the owner did not want it repaired.
Deputy Adolph expressed surprise at this and stated to me that he had been patrolling Miller Road 2 every day since Ike and had not seen a hole in the fence until that day. I informed the deputy that after hurricane Ike I had propped up the broken section of fence and that was why he had not noticed it being down when he had been patrolling Miller Road in previous days and that the horses must have knocked it down recently.
Upon learning of the situation Deputy Adolph stated that he owned five horses himself and (is also a Mounted Patrol member) that in his opinion as both a horse owner and a law enforcement officer the hole in the fence posed a danger to the lives of not only the horses but posed a danger to anyone driving on Miller Road 2 as well. He stated that he wanted the fence fixed because he would much rather have the fence repaired than have to work an accident scene that could result in injury or death to both the horses and to anyone driving on Miller Road. Deputy Adolph was obviously right so I repaired it immediately and did not ask for Dr. Mitten’s approval of the repairs first.
When Dr. Mitten found out that I had repaired the fence he was at first mad, but after I told him that law enforcement was involved and I had been warned of the consequences of not repairing the fence by law enforcement, he stated that since he could no longer deny knowledge of the hole in the fence that it was probably best to just repair it and take the loss. Dr. Mitten also stated that he should have already taken pictures of the fence anyway. I was kindly forgiven (this time) for putting the lives of people traveling down Miller Road 2 and the horses in my care above Dr. Mitten’s loss of perhaps Thirty (30) dollars at most as the only damage was to two (2) 4” X 4” X 8’ posts that were broken. The (3) 1” X 6” X 14’fence boards were not damaged.
3) The plaintiff’s agent and friend known to me as Edger, with the plaintiff’s knowledge, knowingly and recklessly also put the general public and a two year old gelding horse in danger of serious bodily injury, and death on or about April 7.
On or about April 1 I asked Sergeant Peeler if he would take a two year old gelding to the office of Dr. Hall; a doctor of veterinary medicine. I informed Sergeant Peeler that the horse had in my opinion been suffering for the past six weeks because I had been forced to separate the horse from his usual companion and keep him in the round pen. This horse had become very unstable and dangerous due to inhumane treatment he received, as Dr. Mitten put it, to prepare him for his hernia operation.
Sergeant Peeler agreed to take the horse to Dr. Hall on or about Monday, April 6, and I informed Dr. Mitten of this. At about noon of April 6 Dr. Mitten called me and said he did not want Sergeant Peeler to take his horse to the vet that day. He further informed me that he did not want any of his horses loaded onto a step up horse trailer, the kind Sergeant Peeler has. I asked Dr. Mitten when was the horse going to be sent to the vet as he was supposed to do it after 4 weeks in the round pen and it had been 6 weeks already. Dr. Mitten told me that he would have Edgar take the horse the next day. I informed Dr. Mitten that his ramp trailer was stuck in the mud. The mud was primarily created by the free dirt Dr. Mitten had insisted be put there by dump truck owners looking for a place to dump their unusable dirt for free.
The next day on or about April 7 Edger arrived with Dr. Mitten’s truck to transport the horse to Dr. Hall. Edgar was also unable to remove Dr. Mitten’s horse trailer from the mud. After failing to extract Dr. Mitten’s trailer from the mud Edgar then decided to take Sergeant Peeler’s trailer without asking his permission first. Edgar then attached Dr. Mitten’s truck to Sergeant Peeler’s trailer. When Edgar discovered that Dr. Mitten’s truck did not have a electrical connection that could be used with Sergeant Peeler’s trailer he stated that we would take the horse to the vet without working lights or trailer brakes, which we did.
About 2 days later I went to Dr. Mitten’s office and told him of Edgar reckless and illegal behavior. I also stated to Dr. Mitten that if a van load of Girl Scouts had hit the back of the trailer doing 60 mph their families would have owned him. Dr. Mitten after being told this said that “Edgar is a cowboy sometimes” and that the matter was nothing to be concerned about.
It is quite clear that the plaintiff’s and their agents have shown a pattern that clearly shows a desire to engage in conduct that recklessly and knowingly puts their horses and the general public at risk of serious injury and death and the presence of law enforcement on the property seriously impairs the plaintiffs ability to escape liability for such acts by making it almost impossible for the plaintiffs to use plausible deniability to escape liability or to hide their actions from law enforcement.
There is no other reasonable explanation, as Sergeant Peeler’s presence on the property offers security, and his expertise in the care, treatment, and training of horses is invaluable on any horse farm. He is always ready to transport any horse that needs medical attention to the veterinarian at his own expense, and is always willing to use his own equipment to do so. Sergeant Peeler does more than anyone else on the farm to help the defendant recognize diseases and or dangers to the horses and to eliminate such dangers, resulting in; no losses due to serious injuries or deaths to any horse on this property since he has been here. This has resulted in huge savings to the plaintiff in veterinarian costs, and losses due to injury and deaths.
Furthermore Sergeant Peeler has replaced the many vertical support beams in the stalls where he stalls his horses, and has replaced much of the lumber in other stalls as well. He has also installed all the gates in these stalls. He has even paid to have a licensed electrician bring the wiring in these stalls up to code, and has done all this at no cost or inconvenience to the plaintiff. I cannot think of a single reason why a legitimate law abiding business would object to his presence on their property or place of business under these circumstances.
Ii
Defendant would show, that he replaced almost the entire plumbing system in the house located at 7108 Miller Road 2 in Harris County Texas, in 2002 and that the house was not habitable and that at this time. And further that the tenants taking care of his horses at this time were living in their own travel trailer on the property, as the house was unlivable. Defendant would further show that the only compensation he received for working 12 hours a day 6 days a week for over six months from February until August was reimbursement for fuel for traveling from his home located at 402 Garner Road, in Pasadena, Texas to 7108 Miller Road 2 in Houston, Texas. Defendant will further show that he was harassed by the plaintiff once all the plumbing work that required skilled labor was done. The defendant will further show that the plaintiff has since August profited by rent, labor, and by having his utilities paid by tenants once the house was made habitable, despite the plaintiff’s promise that the defendant could live in the house rent free once it was made habitable.
Iii
Defendant would show, that when he entered into the written contract in 2008 the house was again uninhabitable due to plumbing problems specifically the bathroom always smelled of sewage even after being cleaned, and that the septic tank regularly overflowed onto the lawn. Defendant was once again promised that he could live in the premises rent free and not have to pay electricity if he made plumbing repairs to the residence. Once it became apparent that these problems were fixed the plaintiff once again began to harass, coerce, and threaten, the plaintiff and officer Peeler and that when this did not work he then retaliated against the plaintiff with notice to vacate the property.
Iv
Defendant would show, that the plaintiff attempted to force the defendant into contractual slavery and that when he was unable to do so, began to threaten and retaliate against the defendant and also threatened deputy Craig Peeler if he did not help the plaintiff to force the defendant into involuntary servitude, by amending the written contract on or about July to include caring for two additional horses owned by Edger. When asked by defendant if there would be any compensation for this the plaintiff refused to even consider compensating the defendant for doing so. And that when the defendant refused to sign the amended contract the result was increased harassment.
Defendant’s object to Plaintiffs exhibit A it is not complete the contract to care for the plaintiff‘s horses (not a lease) was amended on or about July 19 and has a second page missing. Furthermore it is not a rental lease at all, as claimed in the suit to evict. It in fact says nothing about rent or compensation to be paid, how much rent is to be paid, or what is being leased or rented. To even call it a lease for rent of a house, or dwelling, is a fraud upon this court.
V
Defendant would show, that when he signed the written contract in 2008 that there were only 4 horses that were to be fed when the contract was signed. And that 4 more horses were brought to the farm shortly after. And that Hurdland and Radioactive Girl were then also brought back to the farm. And that the plaintiff then bought two more horses that were then also brought back to the farm. And that two more horses, a stud and a gelding were then brought back from a trainer. I only agreed to care for 4 horses when I signed the contract, which contained little or no consideration for the defendant other than the right to keep some horses here with the plaintiff’s permission. What started out as a contract to feed 4 horses quickly turned into the feeding, medical treatment and all other necessary care for 12 horses.
Iv
Defendant would show, Dr. Mitten was personally served with a notice demanding that health and safety issues on the property be addressed on August 22, defendant‘s exhibit A.
The defendant contends that he did not receive a certified written notice on August 14. The notice claims to be sent certified mail number 7005 0390 0000 6669 6463. Defendant’s objects to Plaintiff’s exhibit B being allowed into evidence until such time as the plaintiffs have produced proof of the existence of this notice, properly addressed, being sent certified mail, as claimed in exhibit B, to the defendant.
The defendant further asserts that they are not in arrears in the rent and that the Plaintiffs have not stated the facts which entitle the complainant to possession and authorize this action under Sections 24.001 - 24.004, of the Texas Property code.
And that Dr. Mitten and his attorney have failed to reply defendants three page written notice dated and signed by Carl Mitten on August 22. The defendant’s further contend that the first proper certified notice to vacate was received on August 27, five (5) days after the plaintiff Carl Mitten signed and dated a Notice (defendant’ exhibit A) informing him of safety and health code violations. Defendant also objects to the Plaintiff’s reply to the defendant’s Second Notice of Safety and Health Issues and demand for an explanation (defendant’s exhibit C) delivered to Carl Mitten on October 05, in which the plaintiff’s contend that the defendant’s acted in bad faith, but did not deny, contend with, or promise to remedy or repair, the health and safety issues raised.
When we first moved into the house I thought that the septic tank was overflowing because too much waste water was going into it. I also at that time thought that the bathroom smelled all the time because there was no P-trap on the shower. Dr. Mitten agreed to pay for the materials and I installed a separate sewage line to the washing machine and the shower. This however did not solve the problem, as I later found out the smell is due to the improper installation of the sewage pipes, and the improper installation of the water closet or toilet. The septic tank may or may not be fixed. I realized that it was being caused by rain water during the recent drought when it worked fine. I have dug a trench to drain off rain water but it may be that the ancient concrete septic tank is cracked, in which case it will again overflow once the ground is saturated with rain.
V
Defendant would show, a second letter was sent to Carl Mitten and his attorney dated August 30 Defendant’s exhibit B, and that a -three page Second Notice of Safety and Health Issues and demand for an explanation was sent via Certified Mail Article Number 7009 1410 0001 3601 4124 defendant’s exhibit C, on October 02, and that the plaintiff’s are slum lords, and that they are in fact the ones acting in bad faith, and are attempting to perpetrate a fraud upon the court with their Exhibit’s A & B.
Defendant would show, the economies of the Justice System and of this Honorable Court, and of the Parties' current and future respective costs and interests, and of the Texas Property Code, Texas Deceptive Fair Trade Act, The Texas Civil Code and the Texas Rules of Civil Procedure, and Local Rules of Court, indicate that the Texas Legislature's stated policies and intents should be applied in this matter.
To someone like the defendant whose knowledge of the law is limited, it certainly appears as if the actual, if not stated intent and purpose of the Legislature in regards to forcible detainer is indeed to deny justice, and due process, to the poor, the afflicted, and the weak, so that the rich, unaffiliated, and the powerful, may deny the laborer and craftsmen fair compensation, and so that the rich and powerful may use the threat of eviction to enslave, threaten, harass, retaliate and take advantage of those less fortunate. The example has been set at the highest levels of government, both state and federal, and it is quite clear that hypocrisy is of no concern to many in the Legislature. However the alleged supreme law of the land clearly states that the defendant is entitled to due process of law and to fair compensation. And that any inferior law that are repugnant to the Constitution of the United States and are null and void and cannot be enforced by anyone who is in fact an honorable person. It is also clear that the constitution may not be amended by acts of the State Legislature, or by acts of congress, but may only be amended by the processes prescribed by the constitution itself. There are other problems as well that are enumerated in the notice.
There is a higher law than even the Constitution however, and that law states, “It is not for kings to drink wine; nor for princes strong drink: Lest they drink, and forget the law, and pervert the judgment of any of the afflicted. Give strong drink unto him that is ready to perish, and wine unto those that be of heavy hearts. Let him drink, and forget his poverty, and remember his misery no more. Open thy mouth for the dumb in the cause of all such as are appointed to destruction. Open thy mouth, judge righteously, and plead the cause of the poor and needy.” Chapter 31 of Proverbs verses 4-9.
Prayer
Defendant hereby prays that this Honorable Court:
1) Order all Parties’; including the party known to me as Edgar, whose full name and address is known to the plaintiffs, to appear before the court within five (5) calendar days of this ANSWER, and MOTION FOR COUNTER BOND being filed and executed, pursuant to the Texas Rules of Civil Procedure PART VII Section 3 RULE 740 (a) (b) or within such reasonable time thereafter as may be practical and as the Parties may mutually agree and file with this Honorable Court; or, alternatively,
2) Should Objection to defendant's motion for relief be timely filed, Set a time, date and place for Hearing upon this answer and motion for counter bond.
3) Defendant’s asks that the court order the plaintiffs to do all necessary repairs necessary to remedy all health and safety problems on the property located at 7108 Miller Road 2, pursuant to sections 92.052 (a), 92.053 (b), 92.054 (c), and 92.056 (a) (b).
4) Defendant’s asks that should the court be convinced that retaliation by the landlord has occurred pursuant to Sec. 92.004, Sec 92.331 (a) 1-3, that relief be granted to the defendants pursuant to Sec 92.331 (b) 1-5, Sec. 92.333 and Sec. 92.335of the Texas Property Code.
5) WHEREFORE, we pray for judgment against the plaintiff and request actual and special damages to justly compensate the defendant for injuries in an amount this court finds just and proper, Plus, punitive or exemplary damages in the amount this court finds just and proper, and costs.
6) Grant such other or additional relief to which defendants may be justly entitled at law or in equity.
trial by jury is demanded herein
Respectfully submitted,
Date:%
SIGNATURE (S):%PRINT NAME: Robert and Virginia Pierson (Defendants Pro Se)
ADDRESS: 7108 Miller Road 2 Houston Texas 77049 (STREET) (CITY) (STATE) (ZIP)
To: Attorney David B. Harberg 1010 Lamar, Suite 450 Houston, Texas 77002
After are conversation today April 19 I am now considering not signing the second Rule 11 Agreement in cause No. 950,733, even if Dr. Mitten does agree to a release. You stated in our recent phone conversation that the judge would probably rule against me if Dr. Mitten’s lawyer again asks the court for a motion to enforce the second rule 11 agreement, that the court would probably grant his motion this time, in your opinion. I would raise several reasons why I believe such a decision would be reversible by a higher court either the 14 court of appeals or the Fifth circuit court of appeals.
1) Neither my wife or myself have signed the second rule 11 agreement. 2) While I did verbally agree to the tentative agreement which we reached after the plaintiffs motion for enforcement of the first rule 11 agreement which was signed by all parties, and violated by the plaintiffs by their own admission, the fact is my wife never agreed, verbally or otherwise. 3) If the agreement was not tentative then why does my copy of the agreement have hand written changes initialed by Phillip Summers attorney for the plaintiff‘s? 4) Unlike the first agreement there is no date on which I am required to accept the agreement.in theory I could accept it the day before trial, so how could the judge rule that I have violated the agreement by not signing it by a certain date when the agreement does not require it? 5) I am disabled with a mental disability and the court in my opinion would be in violation of the American’s With Disabilities Act, and the Constructional rights to equal protection of the law, and to competent and timely appointed legal representation if it were to deny me my right to a trial by jury.
As I said the Plaintiff’s have conceded before the court that they violated the first rule 11 agreement negotiated by you (David B. Harberg) after being appointed by the court a few days before the first date set for a jury trial. Their was no sanctions or consequences for this deliberate violation by the corporate plaintiffs, and the court allowed the plaintiff’s their right to their day in court even after this violation. Is the court now, after doing this, going to discriminate against the disabled and enforce an unsigned, verbal, tentative agreement, made by only one of the parties, and that party the only mentally ill person present?
If there is a hearing I want to exercise my right to have the hearings audio recorded for the purposes of appeal. Also as I am sure you know the appeals court can only consider what is on the record so I am also going to need you to raise the issue of the discriminatory nature of the Justice of the Peace hearings which deny equal protection of the law as well. They have no authority to force land owners to correct health and safety violations but they can make the disabled homeless without due process or legal representation.
I also believe that the property code is in violation of the constitution in several regards. 1) It provides that health and safety code violators can violate a persons right to exercise their constitutional and other legal rights if they claim that a defendant has not paid his rent, or has acted in bad faith, etc, etc. 2) The constitutions of the U.S. And the state of Texas both state that the state legislature may not revoke a constructional right except by amending the Constitution. Furthermore it is not equal protection of the law if corporate entities are not equally sanctioned for bad faith, contractual violations, health code violations, etc. The Texas Property code cannot punish a disabled individual for refusing to be contractually enslaved, and reporting serious health and safety code violations, and reward corporations for endangering the public, contractual breaches, and violating the constructional and human rights of the poor and afflicted and still honestly call itself an honorable and just court.
I also want to cite the learned treatises of historian Dr. Henry Steele Commager: “The intolerance of the thirties and the forties had not even the dignity of intelligence or accuracy, or of a moral purpose. Those who proclaimed undying devotion to the Constitution had not bothered to read that document, and the Declaration of Independence was similarly terra incognita to them. They arrogated to themselves the guardianship of the American tradition without knowing any more about the American than the Mexican tradition; they were dogmatic about traditional American economic virtues without familiarizing themselves with the most elementary facts of American economic history; they announced as law doctrines that had been consistently repudiated by the Supreme Court. (pp. 412-414)
The nineteenth century, in its felicity, had thought sufficient the guarantees of the Constitution and the Bill of Rights. The actual content and incidence of these guarantees—what they meant to the industrial worker, the immigrant, the Negro—received little consideration: certainly we look in vain in the treatises of the commentators from Story to Burgess for any analysis of political and civil rights that went behind the glittering promises to the commonplace actualities. Men had come to repeat the familiar phrase of the Declaration of Independence and the Bill of Rights, thoughtlessly and automatically, as they intones the Apostles' Creed or college songs.
Perhaps the most important product of the new political realism was a livelier apprehension of the interdependence of liberty and security. What did the right to vote mean to a Mississippi Negro; what did the privileges and immunities clause mean to Steinbeck's Okies; what did the rights of free speech and assembly mean to CIO organizers in Jersey City? Of what value was the guarantee of due process of law to a Negro confronted by a white jury in a case involving the honor of a white woman? What was the price of freedom of worship to Jews who paid for orthodoxy by social ostracism? What did freedom of contract mean to a charwoman, except that she was permitted to work ten hours instead of eight and saved from the dangerous regimentation implicit in a minimum wage? (page 341)”
The following are sections of the ADA Title II that the defendant/complainant wishes to cite in support of the above allegations.
II-1.2000 Public entity. A public entity covered by title II is defined as (2) Any department, agency, special purpose district, or other instrumentality of a State or local government.
II-1.4200 Other Federal and State laws. Title II does not disturb other Federal laws or any State laws that provide protection for individuals with disabilities at a level greater or equal to that provided by the ADA. It does, however, prevail over any conflicting State laws.
II-3.3000 Equality in participation/benefits. The foundation of many of the specific requirements in the Department’s regulations is the principle that individuals with disabilities must be provided an equally effective opportunity to participate in or benefit from a public entity’s aids. Benefits. And services.
II-3.5300 Safety. A public entity may impose legitimate safety requirements necessary for the safe operation of its services. Programs, or activities. However, the public entity must ensure that its safety requirements are based on real risks not on speculation, stereotypes, or generalizations about individuals with disabilities.
II-3.6100 General. A public entity must reasonably modify its policies, practices, or procedures to avoid discrimination. If the public entity can demonstrate, however, that the modifications would fundamentally alter the nature of its service, program, or activity, it is not required to make the modification.
II-3.1100 Retaliation or coercion.individuals who exercise their rights under the ADA, or assist others in exercising their rights, are protected from retaliation. The prohibition against retaliation or coercion applies broadly to any individual or entity that seeks to prevent an Individual from exercising his or her rights or to retaliate against him or her for having exercised those rights. Any form or retaliation or coercion, including threats, intimidation, or interference, is prohibited if it interferes with the exercise of rights under the Act.
I hereby request from the court and all parties to this case for reasonable accommodation pursuant to the Americans With Disabilities Act.
Robert Pierson 7108 Miller Road 2Houston, Texas
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