NO. 03-1069

 COMPANION TO: 03-978, 03-0990, 03-1022, 03-1023, 03-1049, 
03-1070, 03-1079, 03-1082, 03-1083, 03-1084. 03-1117, 03-1139

 IN THE

SUPREME COURT

OF TEXAS

 ______________________________

 IN RE:

JOHN WORLDPEACE

______________________________

   Re:  Cause No. 2002-42081; Commission for Lawyers Discipline v. John WorldPeace, 269th District Court 
Harris County , Texas

______________________________________________________________________

 RELATOR WORLDPEACE’S REPLY TO
COMMISSION FOR LAWYER DISCIPLINE'S 
RESPONSE TO WORLDPEACE’S
MOTION TO STAY JUDGMENT FOR DISBARMENT

______________________________________________________________________

                                                                        Filed by: John WorldPeace, Relator  

                                                                        John WorldPeace
                                                                       
2620 Fountainview,
Suite 106   
                                                                       
Houston , Texas 77057
                                                                       
Tel. 713-784-7618
                                                                       
Fax. 713-784-9063
                                                                       
TBA# 21872800

TO THE HONORABLE JUSTICES OF THIS COURT

            COMES NOW, Relator and files this RELATOR WORLDPEACE’S REPLY TO COMMISSION FOR LAWYER DISCIPLINE’S RESPONSE TO WORLDPEACE’S MOTION TO STAY JUDGMENT OF DISBARMENT and would show the court the following:

            1) WorldPeace has filed three reply’s to the Commission for Lawyer Discipline’s response.  Two were filed before WorldPeace received the Commission for Lawyer Discipline’s responses on Monday, March 8, 2004 , and one afterwards.  Two were titled replies and one was titled a supplemental reply.

            2) a) An Application for Writ of Mandamus is an original proceeding with its own cause number.  There is no rule in the TRAP which disallows a Motion to stay to be filed under a Mandamus petition.

            b)  An Application for Writ of Mandamus is an original proceeding with its own cause number.  It is irrelevant that WorldPeace also filed the same Motion in his appeal pending in the Fourteenth Court of Appeals, Harris County, Texas (Cause No. 14-03-01339-CV; John WorldPeace v. Commission for Lawyer Discipline).

            c) No Application for Writ of Mandamus that WorldPeace has filed has been finally denied on the merits.  A denial to hear an Application for Writ of Mandamus is meaningless.  There is no rule prohibiting WorldPeace from refiling an Application for Writ of Mandamus in the Appeals Court if the Supreme Court refuses to hear it.  Further, there is a Motion for Rehearing pending in the Fourteenth Court of Appeals regarding Cause No. 14-04-00042-CV.  The matter is not final as alleged by Ms. Acevedo.

            Further, Ms. Acevedo failed to inform the court that the Fourteenth Court of Appeals has also requested the Commission for Lawyer Discipline to respond to WorldPeace’s Motion to Dismiss the Appeal for Want of Jurisdiction because the Judgment for Disbarment is interlocutory.  Ms. Acevedo filed a response.

SUMMARY

            There is nothing in the Commission for Lawyer Discipline’s response that speaks to the core issue of the Motion to Stay: “Can any court selectively enforce part of the TRDP against a respondent attorney and not enforce other parts of the TRDP against the Commission for Lawyer Discipline?  Either the entire TRDP is valid or it is a farce.  If one section is invalid, then it is up to the appellate courts to so state in a ruling.  Until such a ruling is made the entire TRDP is valid and to selectively enforce it against the respondent attorneys and not against the Commission for Lawyer Discipline’s attorneys is simply unconstitutional because it denies the respondent attorney equal protection under the law.  This is very basic law.

            It is WorldPeace’s position that the TRDP is defective and corrupt in its application by the Commission for Lawyer Discipline.  Apparently Ms. Acevedo agrees because she offered not a scintilla of explanation about the selective enforcement of the TRDP.  Ms. Acevedo did not even attempt to distinguish Rule 3.01 TRDP and Rule 3.14 TRDP in such a way that Rule 3.01 should not be enforced and that Rule 3.14 should be enforced.

PRAYER

            WHEREFORE, premises considered, WorldPeace prays this court to stay the August 27, 2003 , Judgment for Disbarment against him until all appeals are exhausted and for such other and further relief in equity or at law that this court may deem proper.

                                                                        Respectfully submitted,

 

                                                                                                                                                                                     
                                                                        John WorldPeace
                                                                       
2620 Fountainview,
Suite 106
                                                                       
Houston , Texas 77057
                                                                       
Tel. 713-784-7618
                                                                       
Fax.  713-784-9063
                                                                       
TBA 21872800  

CERTIFICATE OF SERVICE

            I certify that a true and correct copy of the foregoing pleading was forwarded to opposing counsel on March 8, 2004, by CERTIFIED MAIL (CMRRR # 7002 2410 0004 3246 6195) and to the Clerk of the Supreme Court of Texas on March 8, 2004, via EXPRESS MAIL (EM # ET574518255US).

                                                                         John WorldPeace


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