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NO. 2002-42081
COMMISSION FOR
LAWYER
§ IN THE DISTRICT COURT
DISCIPLINE
§
§
V. §
§
JOHN WORLDPEACE § 269TH JUDICIAL DISTRICT
WORLDPEACE’S
SUPPLEMENTAL ANSWER AND COUNTERCLAIM
TO
THE HONORABLE JUDGE OF THIS COURT
On
or about April 28, 1999, WorldPeace entered into a Retainer Fee Agreement with
Defendant whereby WorldPeace would substitute into an ongoing lawsuit (Cause No. 715,017: In the
County Civil Court at Law Number Two; Harris County, Texas) in which
Defendant was trying to recover title to a 1979 For Semi-Tractor and a 1983
Lufkin Trailer; said title being in the name of Alvin Arbuckle.
WorldPeace
substituted into the lawsuit which was called to trial on January 1, 2000. Per the final judgment in that
lawsuit, title to the $22,000.00 tractor/trailer was vested in Defendant and in
addition Defendant was awarded $3,000.00 in damages. Therefore, the total amount awarded to
Defendant in that lawsuit was $25,000.00.
From
the date of the final judgment up to the date of this Motion for Summary
Judgment, WorldPeace has collected and
maintained in his possession $1,000.00 from Arbuckle, Defendant in the
underlying lawsuit.
Defendant
Collins has refused to pay WorldPeace one cent of his fee per the Retainer Fee Agreement.
CAUSES OF ACTION AND DAMAGES
WorldPeace
sues Defendant for fraud, breach of contract and quantum meruit and alleges actual damages in excess of
$10,000.00. As the fraudulent acts of
Defendant were committed with actual malice,
WorldPeace sues Defendant for exemplary damages.
II. FACTS REGARDING SLANDER, INVASION OF PRIVACY
AND
INTENTIONAL
INFLICTION OF EMOTIONAL DISTRESS
WorldPeace
represented Defendant in Cause No.
715,017; Collins v. Arbuckle; CCCL No. Three,
Harris County, Texas. Due to the
efforts of WorldPeace, Defendant prevailed in that case and recovered the equivalent
of $15,000. Defendant per her contract
with WorldPeace
Prior to WorldPeace filing
suit, Defendant filed a complaint with the State Bar of Texas against
WorldPeace. The Defendant was repeatedly
warned by the State not to reveal anything about the
grievance to anyone other than her attorney or the Chief Disciplinary Counsel.
WorldPeace
filed a Motion for Summary Judgment in Cause
No. 2000-31108 and Defendant filed a
response on October 21, 2000.
In
said response, Defendant revealed on the front page of said response the fact
that she had filed a grievance on WorldPeace.
In
addition on page 5 of Defendant’s affidavit supporting her Response to
WorldPeace’s Motion for Summary Judgment, Defendant incredibly quoted the State
Bar’s warning to her regarding revealing anything about the grievance
and then state that “A panel apparently
made a ruling on July 18, 2000, and it is my understanding that Attorney
WorldPeace gave notice of appeal and the matter is set for trial in mid
November, 2000.”
WorldPeace
would show the court that Defendant’s statement is incorrect.
ARGUMENT
Every
person in general and the State Bar in specific understands that a lawyer’s
Reputation is critical to his
success in practicing law. That is why
the State Bar demands that its
Grievance proceedings be kept
absolutely confidential until such time as a settlement is reached with the
lawyer for sanctions or suit is actually filed in the District Court. If no wrongful acts are
The
purpose of the State Bar rules is to prevent individuals like Defendant from
using the Grievance process to gain ad
advantage in a lawsuit; just exactly what the Defendant is attempting in this lawsuit.
Defendant
is a practicing nurse and is fully aware of the importance of reputation in the
field of law because it is also important in the field of medicine.
Defendant intentionally, knowingly and maliciously made public the groundless grievance she filed against WorldPeace. In addition, Defendant intentionally, knowingly and maliciously lied with regard to WorldPeace being sued by the State Bar. If in fact the State Bar had filed suit against WorldPeace, said lawsuit would be on file in the Ancillary Court on the first floor of the Harris County courthouse; which it is not because no such suit exists.
In
an attempt to avoid paying WorldPeace his fees in the Collins v. Arbuckle suit, Defendant filed a meritless
grievance with the State Bar and then in a further attempt to use the grievance
process as a lever to avoid paying WorldPeace his fees, Defendant, contrary to
the specific warnings of the State Bar
made her grievance a part of the public record; all to the severe detriment of WorldPeace’s
reputation.
Now,
due to the malicious acts of Defendant, WorldPeace will have to contend with other attorneys referencing said
slanderous statements by Defendant.
WorldPeace’s reputation has been irrevocably tarnished by the
intentional acts of Defendant.
CAUSES OF ACTION AND DAMAGES
WorldPeace
sues Defendant for intentional infliction of emotional distress and alleges Actual damages in excess of
$100,000.
As
the acts of Defendant were committed with actual malice, WorldPeace sues for exemplary damages.
PRAYER
WHEREFORE, premises considered,
WorldPeace prays that Defendant be served and answer and that WorldPeace have
judgment against Defendant and all the relief at law and in equity to
which his is justly entitled.
Respectfully
submitted,
__________________________________
John
WorldPeace
TBA
No. 21872800
2620
Fountain View, Suite 106
Houston,
Texas 77057
Tel: 713-784-7618
Fax: 713-784-9063
CERTIFICATE OF
SERVICE
I certify that a true and correct
copy has been delivered to opposing counsel by fax on August
5, 2003.
______________________________
John
WorldPeace
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