UNITED STATES DISTRICT
COURT
FOR THE WESTERN DISTRICT OF TEXAS
EL PASO DIVISION
)Brandon Callier, Pro se,
Ana Callier, Pro se,
)Craig Cunningham, Pro se
)Plaintiff
)
COMPLAINT
) v. CIVIL ACTION NO. EP07CA0226)
)Billie Bauer aka
Creditwrench
)Defendant
ORDER
OF THE COURT
Comes
now the Defendant, Billie E. Bauer, Pro Se, and pursuant to his
motion for more
definite statements from the Plaintiffs
respectfully moves this Honorable Court to order
that for
the purposes of determining the commonality of the causes of the
Plaintiffs and
provide the Defendant with sufficient
information to properly formulate his defenses that
each
and every one of the Plaintiffs be required to provide to the Court
and to the
Defendant the following definitive statements:
(A) Be it furthermore ordered and decreed that each of the
Plaintiffs state whether or not
a spousal or
intimate relationship exists or has ever existed with the Defendant?
If so,
such spousal or intimate relationship shall
be fully and completely described and
outlined in
the Plaintiff's own words, sworn and subscribed to under penalty of
perjury.
(B) Be it hereby ordered and decreed that each of the Plaintiffs
shall state whether or not
the Defendant crossed any
state line or entered or left Indian country with the intent
to injure, harass, or intimidate one's spouse or intimate
partner,
approximate date(s)
of such crossing, which state
line or Indian country was crossed, and specifically
what words spoken or printed or what behavior led the Plaintiff to
believe that the
Defendant had an intent to injure,
harass or intimidate Plaintiff's spouse or intimate
partner and the name of that spouse or intimate partner.
(C)
It is hereby ordered and decreed that each Plaintiff shall
specifically state whether or
not in the course of
or as a result of such travel, the Defendant intentionally
committed a crime of violence and if any such crime of
violence is alleged state what
crime of violence
the Defendant committed, the time and place of such crime of
violence, what weapons were used in the commission of such
crime of violence and
whether or not a police report
was filed at the earliest possible time, with what police
agency such police report was filed and the official file number
associated with the
report if any.
(D) It is
hereby further ordered and decreed that Plaintiff is hereby further
ordered to
specifically state whether or not in the
course of such travel alleged the Defendant
caused any
bodily injury to the spouse or intimate partner of the responding
Plaintiff
and if so what bodily injury Defendant
caused, and whether or not such bodily injury
was
treated at a hospital or by a physician as well as date and time
spouse or intimate
partner was treated and by what
hospital or physician.
(E) Be it further
ordered and decreed that each Plaintiff specifically state whether
or not
the Defendant engaged in harassing behavior,
what the alleged harassing behavior
consisted of that
caused the claimant Plaintiff to fear for the claimant Plaintiff's
safety
or the safety of a member of the claimant
Plaintiff's family or the claimant Plaintiff's
property.
(F)
Be it further ordered and decreed that the Plaintiff shall state
whether or not the
Defendant violated a restraining
order prohibiting the alleged harassing behavior,
which court of law issued the restraining order and state the date
upon which such
restraining order was issued.
(G)
Be it further ordered and decreed that the Plaintiff shall state
whether or not the
Defendant engaged in harassing
behavior, by acts or words threatened to inflict
bodily injury on the claimant or to commit an offense against the
claimant, a
member of the claimant's family, or the
claimant's property and that the Defendant
had the
apparent ability to carry out the threat; that the Defendant's
apparent ability
to carry out the threat caused the
claimant to reasonably fear for the claimant's
safety or the safety of a family member, that the claimant at least
once clearly
demanded that the Defendant stop the
Defendant's harassing behavior and that after
the
demand to stop by the claimant Plaintiff, the defendant continued
the harassing
behavior; and the harassing behavior
has been reported to police as a stalking
offense. The claimant Plaintiff shall, as part of the proof
of the behavior described
above submit evidence
other than evidence based on the claimant Plaintiff's own
perceptions and beliefs.
(3) Be it further ordered
and decreed that each Plaintiff shall state in their own words
sworn to under penalty of perjury what statements allegedly
made by the Defendant
were false, flat wrong,
libelous in nature, and how they harmed each and every
Plaintiff named party to this instant case, the amount of damages
resulting from the
alleged libelous statements and
how those damages were calculated. If statutory or
punitive damages are alleged Plaintiff must state the exact statute,
section and
subsection authorizing them as well as
the conditions under which they are authorized
and the
method of proof authorizing this Honorable Court to assess them.
(4) Be it furthermore ordered and decreed that each and every
Plaintiff shall state
whether or not they are
connected to CCH Consulting LLC, a New Mexico
Corporation whose registered agent for service of process is Incorp.
Inc. of Las Vegas
Nevada and if so connected to CCH
Consulting LLC show proof that the corporate
charter
of that corporation specifically authorizes them to act in behalf of
that
corporation and what actions they are authorized
to perform and specifically whether
or not the
corporate charter authorizes them to act in the capacity of Pro Se
attorney
before courts of law to represent the
interests of the corporation.
(5) Be it furthermore ordered and decreed that Plaintiffs Craig
Cunningham and
Brandon Callier shall state and show
proof that the corporate charter of CCH
Consulting
LLC authorizes the corporation to do business as a credit repair
organization and if so state under penalty of perjury that
corporation was in
compliance with all of the laws of
the State of Texas at the time of filing this instant
case including but not necessarily limited to the requirements of
the Texas Secretary
of State which are to be
registered as a Texas corporation or as a foreign corporation
as well as having complied with the requirements of the Texas
Finance Code which
demands license and bond among
other things.
(6) Be it furthermore
ordered and decreed that Plaintiffs Craig Cunningham and
Brandon Callier shall state with specificity how Defendant's
alleged statement that
Plaintiff Ana Callier is
associated with CCH Consulting LLC has harmed or damaged
CCH Consulting or would harm CCH Consulting LLC in the future.
______________________________________
Judge
_____________________________________
Billie
E. Bauer, Defendant Pro Se, July 13th, 2007
1604 SW 28th
St.
Oklahoma City, Oklahoma 73108
405-616-7901
Motion for injunctive relief page 1
Motion for injunctive relief page 2
Motion for injunctive relief page 3
Motion for injunctive relief page 4
Bauer's motion for more definite statement
Bauer's objection to motion for injunctive relief
Defendant's motion for order of the court demanding a more definite statement
Callier vs Bauer order of the court(2)
