Plaintiff, Defendants.

Transcription

1 CAUSE NO VICKI ISAACKS and BRUCE ISAACKS, IN THE DISTRICT COURT Plaintiff, 367 TH JUDICIAL DISTRICT WILLIAM TRANTHAM, SHANE ALLEN, BOB WEIR, STEPHEN WEBSTER, and THE NEWS CONNECTION GROUP, INC., Defendants. DENTON COUNTY, TEXAS PLAINTIFF VICKI ISAACKS' S TO DEFENDANT WILLIAM TRANTHAM' FIRST REQUESTS FOR ADMISSION TO: Defendant, WILLIAM TRANTHAM, by and through his attorney of record Chris Raesz of Chris Raesz, P., 306 North Carroll Blvd., Denton, Texas COMES NOW Vicki Isaacks ("Plaintiff' ) and serves these her Responses to Defendant Wiliam Trantham s First Requests for Admission. Respectfully submitted FRIEDMAN & FElGER, L.L.P. BY: Lawrence J. Friedman State Bar No Marla Pittman State Bar No Spring Valley Road, Suite 200 Dallas, Texas (972) (Telephone) (972) (Telecopier) ATTORNEYS FOR PLAINTIFFS

2 CERTIFICATE OF SERVICE, MARLA PITTMAN, do hereby certify that a true and correct copy of the foregoing document was forwarded to all counsel of record, on this the April 2007, pursuant to the Texas Rules of Civil Procedure ay of MARLA PITTMAN

3 Responses to Reauests for Admissions County, Texas District Attorney. : Admit You are a former employee of the Dallas Dallas County, Texas District Attorney. Deny You are not a former employee of the of Irving, Texas. : Admit You are a former employee of the City City of Irving, Texas. Deny You are not a former employee of the You were employed as a legal advisor to the City of Irving, Texas Police Department. : Admit You were not employed as a legal advisor to the City of Irving, Texas Police Department. : Deny Your husband was the Criminal District Attorney of Denton County, Texas for a portion of the time you were employed by the City of Irving, Texas. : Admit You were not a client of the Denton County, Texas Criminal District Attorney s Civil Division while you worked for the City of Irving, Texas. Plaintiff objects to this request on the grounds that the response to Plaintiff further objects to this request on the grounds that it is

4 incomprehensible. To the extent that Plaintiff believes she understands what she is being requested to admit or deny, Plaintiff admits this The City of Irving, Texas was not a client of the Denton County, Texas Criminal District Attorney s Civil Division during your employment by the City of Irving, Texas. Plaintiff objects to this request on the grounds that the response to Subject to said objection and without waiving same, Plaintiff cannot knowledge of the request's subject matter to REQUEST FOR ADMISSION NO. 10: You were acquainted with the attorneys in the offce of the Denton County, Texas Criminal District Attorney Civil Division during your employment with the City of Irving, Texas. Plaintiff objects to this request on the grounds that the response to 11 You asked one or more of the Denton County, Texas Criminal District Attorney s Civil Division attorneys to provide you with one or more legal memoranda while you were employed by the City of Irving, Texas. Plaintiff objects to this request on the grounds that it is overly broad and not suffciently narrow in scope to allow Plaintiff to singularly admit or deny same. : You received from the Denton County, Texas Criminal District Attorney s Civil Division one or more legal memoranda while you were employed by the City of Irving, Texas. Plaintiff objects to this request on the grounds that it is overly broad and not sufficiently narrow in scope to allow Plaintiff to singularly admit or deny same. 13: You received from the Denton County, Texas Criminal District Attorney Civil Division one or more documents containing legal research performed by any individual employed by the Denton County, Texas Criminal District Attorney s Civil Division while you were employed by the City of Irving, Texas.

5 Plaintiff objects to this request on the grounds that it is overly broad and not suffciently narrow in scope to allow Plaintiff to singularly admit or deny same. Plaintiff further objects to this request on the grounds that it is incomprehensible. REQUEST FOR ADMISSION NO. 14: You provided one or more legal memoranda prepared by the Denton County, Texas Criminal District Attorney Civil Division to the City of Irving, Texas Police Department during your employment by the City of Irving, Texas. : Plaintiff objects to this request on the grounds that it is overly broad and not sufficiently narrow in scope to allow Plaintiff to singularly admit or deny same. REQUEST FOR ADMISSION NO. 15: You provided the contents of any document prepared by any individual employed by the Denton County, Texas Criminal District Attorney Civil Division to the City of Irving, Texas Police Department during your employment by the City of Irving, Texas. Plaintiff objects to this request on the grounds that it is overly broad and not suffciently narrow in scope to allow Plaintiff to singularly admit or deny same. Plaintiff further objects to this request on the grounds that it is incomprehensible. 16: No Contract for goods or services existed between the City of Irving, Texas and Denton County, Texas Criminal District Attorney s Civil Division during your employment with the City of Irving, Texas. : Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request' s subject matter to REQUEST FOR ADMISSION NO. 17: You made an agreement with Jake Coller for him to not be a candidate in any election for Judge of the 393rd Judicial District Court of Denton County, Texas in exchange for the support of your husband in any other election for which Jake Coller would be a candidate. Plaintiff objects to this request on the grounds that it incomprehensible. To the extent that Plaintiff believes she understands what she is being requested to admit or deny, Plaintiff denies this

6 18 : You made an agreement with Jake Coller for him to not be a candidate in any election for Judge of the 393rd Judicial District Court of Denton County, Texas in exchange for the support of your husband in any other election for which Jake Coller would be a candidate. : This request is duplicative of the first No. 17. Plaintiff refers Defendant to her response to the first Request for Admission No : Your husband agreed to support Jake Coller in his election for offce if the said Jake Coller would not be a candidate in the primary election for the 393 Judicial District Court of Denton County Texas for which you were a candidate in order for your election as Judge of the 393rd Judicial District Court of Denton County, Texas to be guaranteed. Plaintiff objects to this request on the grounds that it incomprehensible. To the extent that Plaintiff believes she understands what she is being requested to admit or deny, Plaintiff denies this 13 sic: Jake Coller agreed with you not Judicial District Court of Denton County, to run in any election involving the 393 Texas where you were a candidate in exchange for the support of your husband in any other future election that Jake Coller would be a candidate. Plaintiff objects to this request on the grounds that it incomprehensible. To the extent that Plaintiff believes she understands what she is being requested to admit or deny, Plaintiff denies this 14 sic: The support of your husband for any election would be a benefit to Jake Coller. Subject to said objection and without waiving same, Plaintiff cannot knowledge of the request's subject matter to 15 sic: The support of your husband was a benefit to Jake Collier. Subject to said objection and without waiving same, Plaintiff cannot knowledge of the request's subject matter to

7 REQUm FORA MISSI0 16 You were aware that your husband and Jake Coller had reached an agreement for Jake Coller to not run against you in exchange for the support of your husband in the next election where Jake Coller would be a candidate. Deny You knew at the time any 16 (sic) agreement was entered between your husband and Jake Coller the terms of such agreement. Plaintiff objects to this request on the grounds that it incomprehensible. To the extent that Plaintiff believes she understands what she is being requested to admit or deny, Plaintiff denies this 17(sic) Your husband supported Jake Coller in the election following your successful unopposed primary candidacy for Judge of the 393 Judicial District Court of Denton County, Texas. Subject to said objection and without waiving same, Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request's subject matter to 18 (sic) this matter. You have suffered no damages in : Plaintiff objects to this request on the grounds that it is not clear as to which "matter" Defendant refers. To the extent that Plaintiff believes she understands what she is being requested to admit or deny, Plaintiff denies this req uest. 19 (sic) to your attorney in this matter. You have not paid any legal fees : Plaintiff objects to this request on the grounds that it is not clear as to which "matter" Defendant refers. Plaintiff further objects to this request on the grounds that the response to same is not calculated to lead to the discovery of evidence relevant to this 20: You have paid legal fees to your attorney in this matter.

8 Plaintiff objects to this request on the grounds that it is not clear as to which "matter" Defendant refers. Plaintiff further objects to this request on the grounds that the response to same is not calculated to lead to the discovery of evidence relevant to this 21 this matter. Your husband has paid all legal fees in Plaintiff objects to this request on the grounds that it is not clear as to which "matter" Defendant refers. Plaintiff further objects to this request on the grounds that the response to same is not calculated to lead to the discovery of evidence relevant to this donations to pay the legal expenses in this matter. : Your husband used his campaign Plaintiff objects to this request on the grounds that it is not clear as to which "matter" Defendant refers. Plaintiff further objects to this request on the grounds that the response to same is not calculated to lead to the discovery of evidence relevant to this 23: Your husband used his campaign donations to pay the legal fees in this matter. This request is duplicative of No. 22. Plaintiff refers Defendant to her response to Request for Admission No. 22. REQUEST FOR ADMISSION NO. 24: Your attorney is being paid with funds donated to any campaign in this matter. : Plaintiff objects to this request on the grounds that it is not clear as to which "matter" Defendant refers. Plaintiff further objects to this request on the grounds that the response to same is not calculated to lead to the discovery of evidence relevant to this Jarvis. : Admit : You know an attorney named Robert : You were employed by the Dallas County, Texas District Attorney at the same time Robert Jarvis was employed by that same agency.

9 Plaintiff objects to this request on the grounds that the response to Subject to said objection and without waiving same, Plaintiff cannot knowledge of the request's subject matter to : Your husband was employed by the Dallas County, Texas District Attorney at the same time Robert Jarvis was employed by that same agency. Plaintiff objects to this request on the grounds that the response to Subject to said objection and without waiving same, Plaintiff cannot knowledge of the request's subject matter to friend. : The attorney Robert Jarvis is your Plaintiff objects to this request on the grounds that the response to : You socialize with Robert Jarvis. Plaintiff objects to this request on the grounds that the response to D. Mulder. : Admit : You know an attorney named Douglas 31 You were employed by the Dallas County, Texas District Attorney at the same time Douglas D. Mulder was employed by that same agency. Plaintiff objects to this request on the grounds that the response to Subject to said objection and without waiving same, Plaintiff cannot knowledge of the request's subject matter to

10 : Your husband was employed by the Dallas County, Texas District Attorney at the same time Douglas D. Mulder was employed by that same agency. Plaintiff objects to this request on the grounds that the response to Subject to said objection and without waiving same, Plaintiff cannot knowledge of the request's subject matter to friend. : The attorney Douglas D. Mulder is your Plaintiff objects to this request on the grounds that the response to : You socialize with Douglas D. Mulder. Plaintiff objects to this request on the grounds that the response to son Adam Isaacks. : Douglas D. Mulder represented your Plaintiff objects to this request on the grounds that the response to 36: Douglas D. Mulder represented your son Adam Isaacks in any criminal matter fied in Denton County, Texas. Plaintiff objects to this request on the grounds that the response to to represent your son Adam Isaacks. : Douglas D. Mulder was not paid by you Plaintiff objects to this request on the grounds that the response to : Douglas D. Mulder was not paid by your husband to represent your son Adam Isaacks.

11 Plaintiff objects to this request on the grounds that the response to represent your son Adam Isaacks. : Douglas D. Mulder was not paid to Plaintiff objects to this request on the grounds that the response to Prior to being elected as Judge in the 393rd Judicial District Court of Denton County, Texas, you had not represented any individual in any type of family law matter. Deny 41: Prior to being elected as Judge in the 393rd Judicial District Court of Denton County, Texas, you had not represented any individual in any type of family law matter. This request is duplicative of No. 40. Plaintiff refers Defendant to her response to Request for Admission No. 40. : Divorce cases are common in the 393rd Judicial District Court of Denton County, Texas. : Admit causes of divorce. : You have become familiar with the Plaintiff objects to this request on the grounds that the response to : You have become familiar the problems caused by divorce to those involved in the divorce. Plaintiff objects to this request on the grounds that the response to

12 : Many divorces are caused by one of the parties having sexual partners outside of marriage. Plaintiff objects to this request on the grounds that the response to 46: Having sexual partners other than a spouse during marriage can cause many different emotional dilemmas for the married individuals. Plaintiff objects to this request on the grounds that the response to : Having sexual partners other than a spouse during marriage can cause problems with the children of the marriage if they are living in the home with the parents. Plaintiff objects to this request on the grounds that the response to : You have presided over matters involving the children of a marriage, where one or more of the parties had an outside romantic interest, seek attention by getting into trouble. Plaintiff objects to this request on the grounds that the response to Bouschor, an attorney in Denton, Texas. : Admit : You are acquainted with David an attorney in Denton, Texas. : Admit : You are acquainted with Duane Coker 51 in Greece during : Admit Duane Coker went on vacation with you

13 you in Greece during : Admit : David Bouschor went on vacation with : The spouses of David Bouschor and Duane Coker went on vacation with you in Greece in : Admit 54: The vacation in Greece in 2005 involved sailing. Plaintiff objects to this request on the grounds that the response to more than two weeks. : Your Greek vacation in 2005 lasted Plaintiff objects to this request on the grounds that the response to expenses of your Greek vacation in : David Bouschor paid part of the Plaintiff objects to this request on the grounds that it is not clear as to which "expenses" Defendant refers. of your Greek vacation in : Duane Coker paid part of the expenses This request is duplicative of No. 56. Plaintiff refers Defendant to her response to Request for Admission No. 56. : The total cost to all parties for the Greek vacation in 2005 exceeded $ Plaintiff objects to this request on the grounds that the response to

14 : The total cost to all parties for the Greek vacation in 2005 did not exceed $ Plaintiff objects to this request on the grounds that the response to vacation exceeded $ : The total cost paid by you for the Greek : Plaintiff objects to this request on the grounds that the response to liigation. 61 vacation did not exceed $ The total cost paid by you for the Greek Plaintiff objects to this request on the grounds that the response to 62: The total cost paid by you and your husband exceeded $ for your Greek vacation in Plaintiff objects to this request on the grounds that the response to REQUEST FOR ADMISSION NO. 63: You did not keep a log of the expenses of your Greek vacation in 2005 as they were incurred. Deny REQUEST FOR ADMISSION Greek vacation in 2005 as they were incurred. : Admit NO. 64: You kept a log of the expenses of your : Any log of the expenses of your Greek vacation in 2005 was made subsequent to your return to the United States from Greece. Deny

15 vacation to Greece in : Admit : You did not take your children on your 67: You left your children at home in Carrolton, Texas, while you and your husband went on vacation in Greece in Plaintiff objects to this request on the grounds that the response to RE UEST FOR ADMISSION NO. criminal law. 68: David Bouschor does not practice : Plaintiff objects to this request on the grounds that the response to criminal law. : David Bouschor has never practiced Plaintiff objects to this request on the grounds that the response to law. : Duane Coker does not practice criminal Plaintiff objects to this request on the grounds that the response to 71 criminal law. Duane Coker has never practiced Plaintiff objects to this request on the grounds that the response to RE UEST FOR ADMISSION NO. donations to Bruce Isaacks. 72: David Bouschor contributed political

16 Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request's subject matter to donations to Bruce Isaacks. : Duane Coker contributed political Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request's subject matter to political donations to Bruce Isaacks. : David Bouschor has not contributed Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request's subject matter to political donations to Bruce Isaacks. : Duane Coker has not contributed Plaintiff cannot admit or deny this request because she does not have suffcient information or knowledge of the request's subject matter to 76: David Bouschor contributed political donations to you. : Admit donations to you. : Deny : Duane Coker contributed political political donations to you. Deny : David Bouschor has not contributed political donations to you. : Admit : Duane Coker has not contributed

17 80: You appointed an attorney, C. Jane Thacker, to represent the father in No , IN THE MATTER OF THE MARRIAGE OF FRANCISCO SOLORZNO AND MARIA SOLORZNO AND IN THE INTEREST OF FRANCISCO SOLORZNO, CHILD. : Plaintiff objects to this request on the grounds that the response to 81 : You appointed an attorney, Darcy Loveless, to represent the mother in No , IN THE MATTER OF THE MARRIAGE OF FRANCISCO SOLORZNO AND MARIA SOLORZNO AND IN THE INTEREST OF FRANCISCO SOLORZNO, CHILD. 82: You appointed an attorney, Russell Welch, as an attorney ad litem to represent the child in No , IN THE MATTER OF THE MARRIAGE OF FRANCISCO SOLORZNO AND MARIA M. SOLORZNO AND IN THE INTEREST OF FRANCISCO SOLORZNO, A CHILD. 83: You ordered the Denton County, Texas Treasury to pay the appointed attorney for services rendered for the benefit of the father in No , IN THE MATTER OF THE MARRIAGE OF FRANCISCO SOLORZNO AND MARIA M. SOLORZNO AND IN THE INTEREST OF FRANCISCO SOLORZNO, A CHILD. : Plaintiff objects to this request on the grounds that the response to 84: You ordered the Denton County, Texas Treasury to pay the appointed attorney for the mother for services rendered for the benefit of the mother in No, , IN THE MATTER OF THE MARRIAGE OF FRANCISCO SOLORZNO AND MARIA M. SOLORZNO AND IN THE INTEREST OF FRANCISCO SOLORZNO, A CHILD.

18 85: You ordered the Denton County, Texas Treasury to pay the appointed attorney for services rendered for the benefi of the child in No , IN THE MATTER OF THE MARRIAGE OF FRANCISCO SOLORZNO AND MARIA M. SOLORZNO AND IN THE INTEREST OF FRANCISCO SOLORZNO, A CHILD. 86: No department of the State of Texas was involved as a litigant in No , IN THE MATTER OF THE MARRIAGE OF FRANCISCO SOLORZNO AND MARIA M. SOLORZNO AND IN THE INTEREST OF FRANCISCO SOLORZNO, A CHILD. 87 : You informed the Denton County, Texas Commissioners Court on September 22, 2005, that the law allowed you to appoint amicus attorneys or ad litem attorneys to represent children. : Admit 88: You never informed the Denton County, Texas Commissioners Court, that the law allowed you to appoint amicus attorneys or ad litem attorneys to represent children. : Deny 89: You informed the Denton County, Texas Commissioners Court on September 22, 2005, that you had paid the appointed attorneys for children involved in matters pending in the 393rd Judicial District Court of Denton County, Texas from the Treasury of Denton County, Texas. Plaintiff objects to this request on the grounds that it incomprehensible. Plaintiff further Qbjects to this request on the grounds that it is overly broad and not sufficiently narrow in scope to allow Plaintiff to singularly admit or deny same.

19 REQUEST FOR ADMISSION NO. 90: You informed the Denton County, Texas Commissioners Court on September 22, 2005, that you ordered the parents involved in matters pending in the 393rd judicial District Court of Denton County, Texas where attorneys were appointed for the benefi of children to reimburse Denton County, Texas. Plaintiff objects to this request on the grounds that it incomprehensible. Plaintiff further objects to this request on the grounds that it is overly broad and not sufficiently narrow in scope to allow Plaintiff to singularly admit or deny same. REQUEST FOR ADMISSION NO. 91 : You informed the Denton County, Texas Commissioners Court on September 22, 2005 that in matters pending in the 393rd Judicial District Court of Denton County, Texas where attorneys were appointed for the benefit of children there was no agency of the State of Texas involved. Plaintiff objects to this request on the grounds that it incomprehensible. Plaintiff further objects to this request on the grounds that it is overly broad and not suffciently narrow in scope to allow Plaintiff to singularly admit or deny same. : C. Jane Thacker was not appointed as an amicus or ad litem attorney for any child in No , IN THE MATTER OF THE MARRIAGE OF FRANCISCO SOLORZNO AND MARIA M. SOLORZNO AND IN THE INTEREST OF FRANCISCO SOLORZNO, CHILD. Plaintiff objects to this request on the grounds that the response to Plaintiff further objects to this request on the grounds that it is overly broad and not suffciently narrow in scope to allow Plaintiff to singularly admit or deny same. : Darcy Loveless was not appointed as an No , IN THE amicus or ad litem attorney for any child in MATTER OF THE MARRIAGE OF FRANCISCO SOLORZNO AND MARIA M. SOLORZNO AND IN THE INTEREST OF FRANCISCO SOLO RZNO, A CHILD. Plaintiff objects to this request on the grounds that the response to

20 You ordered paid from the Denton 94: County, Texas Treasury an attorney not appointed by you for services rendered to the father in No , IN THE MATTER OF THE MARRIAGE OF FRANCISCO SOLORZNO AND MARIA M SOLORZNO AND IN THE INTEREST OF FRANCISCO SOLORZNO, A CHILD. Plaintiff objects to this request on the grounds that it incomprehensible. Plaintiff further objects to this request on the grounds that it is overly broad and not suffciently narrow in scope to allow Plaintiff to singularly admit or deny same. 95: You ordered paid from the Denton County, Texas Treasury attorneys C. Jane Thacker, Darcy Loveless and Sherry Shipman for services not rendered as amicus or ad litem attorneys for any child in No, , IN THE MATTER OF THE MARRIAGE OF FRANCISCO SOLORZNO AND MARIA M. SOLORZNO AND IN THE INTEREST OF FRANCISCO SOLORZNO, A CHILD. Plaintiff objects to this request on the grounds that it incomprehensible. Plaintiff further objects to this request on the grounds that it is overly broad and not suffciently narrow in scope to allow Plaintiff to singularly admit or deny same. 96: Your communication to the Denton County, Texas Commissioners Court on September , did not inform the Denton County, Texas Commissioners that you were ordering the Denton County, Texas Treasury to pay for services rendered to private parties by attorneys appointed by you for services rendered not as amicus or ad litem attorneys for children in divorces. Plaintiff objects to this request on the grounds that it incomprehensible. Plaintiff further objects to this request on the grounds that it is overly broad and not suffciently narrow in scope to allow Plaintiff to singularly admit or deny same. 97: Your communication to the Denton County, Texas Commissioners Court on September did not inform the Denton County, Texas Commissioners that you had ordered the Denton County, Texas Treasury to pay for services rendered to private parties by attorneys appointed by you for services rendered not as amicus or ad litem attorneys for children in divorces. : Plaintiff objects to this request on the grounds that it incomprehensible. Plaintiff further objects to this request on the grounds that it is overly broad and not suffciently narrow in scope to allow Plaintiff to singularly admit or deny same.

21 98: Your communication to the Denton County, Texas Commissioners Court on September did not inform the Denton County, Texas Commissioners you were ordering paid from the Denton County, Texas Treasury attorneys appointed by you for parents of children. Plaintiff objects to this request on the grounds that it incomprehensible. Plaintiff further objects to this request on the grounds that it is overly broad and not suffciently narrow in scope to allow Plaintiff to singularly admit or deny same. 99: Your communication of September to the Denton County, Texas Commissioners was deceptive. Deny 100: Your communication of September to the Denton County, Texas Commissioners was accurate in every detail. Plaintiff cannot admit or deny this request because she does not have suffcient information or knowledge of the request' s subject matter to 101 : You did not tell the Denton County, Texas Commissioners in your of September 22, 2005, about all the individual types of appointments you ordered in the 393rd Judicial District Court of Denton County, Texas. Plaintiff cannot admit or deny this request because she does not have suffcient information or knowledge of the request's subject matter to 102: You are aware the State of Texas has a Constitution. : Admit 103: You are unaware the State of Texas has a Constitution. Deny 104: You are aware that the Texas Constitution forbids payments from the public treasury for private purposes.

22 Subject to said objection and without waiving same, Plaintiff cannot knowledge of the request's subject matter to REQUEST FOR ADMISSION NO. 105: You are unaware that the Texas Constitution forbids payments from the public treasury for private purposes. Subject to said objection and without waiving same, Plaintiff cannot knowledge of the request's subject matter to REQUEST FOR ADMISSION NO. 106: You do not have a propert interest in the funds of the Denton County, Texas Treasury. : Plaintiff objects to this request on the grounds that the response to Subject to and without waiving said objection, Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request's subject matter to REQUEST FOR ADMISSION NO. 107: You have a propert interest in the funds of the Denton County, Texas Treasury. Subject to and without waiving said objection, Plaintiff cannot admit or deny this request because she does not have suffcient information or knowledge of the request's subject matter to REQUEST FOR ADMISSION NO. 108: You do not have any discretion, other than that provided by law, to determine the manner in which the funds of the Denton County, Texas Treasury are to be spent. : Plaintiff objects to this request on the grounds that the response to Subject to said objection and without waiving same, Plaintiff cannot knowledge of the request's subject matter to

23 109: You have discretion, other than that provided by law, to determine the manner in which the funds of the Denton County, Texas Treasury are to be spent. Subject to said objection and without waiving same, Plaintiff cannot knowledge of the request's subject matter to 110: Any payment ordered by you for payment to anyone for goods or services for a private purpose from the Denton County, Texas Treasury, other than for indigent parents in a suit brought by the State of Texas for termination of the parent child relationship or an indigent part facing incarceration, was done so without lawful authority. Subject to said objection and without waiving same, Plaintiff denies this 111 : You cannot effectively consent to any payment from the Denton County Texas Treasury for anything other than goods or services for a public purpose. Plaintiff further objects to this request on the grounds that it incomprehensible. 112 Payment to attorneys for services rendered in any District Court other than in matters involving the termination of parental rights or the incarceration of the individual is not for a public purpose. Subject to said objection and without waiving same, Plaintiff denies this 113: You were questioned by Brad Freeman about your ability to pay attorneys for services rendered to non-indigent private litigants or private litigants at all.

24 114: You told Brad Freeman you had a way to pay attorneys for private work in your court. 115: You never told the Denton County, Texas Commissioners that you were paying attorneys for work done for parents in divorces in your court where the State of Texas was not a part until after August, Plaintiff further objects to this request on the grounds that it is overly broad and not suffciently narrow in scope to allow Plaintiff to singularly admit or deny same. 116: After October 1, 2005, you never again ordered attorneys paid from the Denton County, Texas Treasury for work done in private divorces. Plaintiff further objects to this request on the grounds that it is overly broad and not suffciently narrow in scope to allow Plaintiff to singularly admit or deny same. 117: You know of no other Judge in Texas who has paid attorneys from the public treasury of their county for services rendered in private divorces. Subject to said objection and without waiving same, Plaintiff denies this req uest. 118: You were informed by other judges in Texas that payment to attorneys for services rendered in private divorces was not lawful.

25 Plaintiff objects to this request on the grounds that the response to Subject to said objection and without waiving same, Plaintiff denies this REQUEST FOR ADMISSION NO. 119: You were informed by other judges in Texas that payment to attorneys for services rendered in private divorces was unauthorized. Subject to said objection and without waiving same, Plaintiff denies this req uest. 120: You were told by other Denton County, Texas Judges prior to August, 2005, that the payments you were making in private divorces from the Denton County, Texas Treasury were not lawful. Subject to said objection and without waiving same, Plaintiff denies this REQUEST FOR ADMISSION NO. 121 : You were told by other Denton County, Texas Judges prior to August, 2005, that you should stop ordering the Denton County, Texas Treasury to make paymen to attorneys in private divorces. Subject to said objection and without waiving same, Plaintiff denies this req uest. REQUEST FOR ADMISSION NO. 122: Your husband represented Denton County, Texas as Criminal District Attorney unti December : Admit REQUEST FOR ADMISSION NO. 123: Your husband was requested by the Denton County, Texas Commissioners to recover any money paid to attorneys from the Denton County, Texas Treasury in private divorces.

26 Subject to said objection and without waiving same, Plaintiff cannot knowledge of the request's subject matter to REQUEST FOR ADMISSION NO. 124: Your husband was requested by the Denton County, Texas Commissioners to recover any money ordered to be paid by you to attorneys from the Denton County, Texas Treasury in private divorces. : Plaintiff objects to this request on the grounds that the response to Subject to said objection and without waiving same, Plaintiff cannot knowledge of the request's subject matter to 125: Your husband was requested by the Denton County, Texas Commissioners to determine the amount of any money paid to attorneys from the Denton County, Texas Treasury in private divorces. Subject to said objection nd without waiving same, Plaintiff cannot knowledge of the request's subject matter tb REQUEST FOR ADMISSION NO. 126: Your husband told you he would represent your interests in the determination of the amount of any money paid to attorneys from the Denton County, Texas Treasury in private divorces. Subject to said objection and without waiving same, Plaintiff denies this REQUEST FOR ADMISSION NO. 127: You told Tom Keever you made no attempt to determine whether or not the parties you appointed lawyers to represent in private divorces were indigent prior to ordering the Denton County, Texas Treasury to pay the lawyers for those services. Subject to said objection and without waiving same, Plaintiff denies this

27 REQUEST FOR ADMISSION the details of the payments to lawyers. NO. 128: You have confided in Hugh Coleman Plaintiff objects to this request on the grounds that the response to REQUEST FOR ADMfSSION NO. 129 Hugh Coleman is not your attorney in this lawsuit. Plaintiff objects to this request on the grounds that the response to titigation. Subject to said objection and without waiving same, Plaintiff admits this 130 Hugh Coleman never has been your attorney in this lawsuit. Plaintiff objects to this request on the grounds that the response to Subject to said objection and without waiving same, Plaintiff admits this 131 : You have confided in L. Dee Shipman the details of the payments to lawyers appointed by you in private divorces. Plaintiff objects to this request on the grounds that the response to 132: You have confided in Sherry Shipman the details of the payments to lawyers appointed by you in private divorces. Plaintiff objects to this request on the grounds that the response to 133: L. Dee Shipman is not your attorney. Plaintiff objects to this request on the grounds that the response to Subject to said objection and without waiving same, Plaintiff admits this

28 134: L. Dee Shipman has not been your attorney. : Plaintiff objects to this request on the grounds that the response to liigation. Subject to said objection and without waiving same, Plaintiff admits this 135: There are no privileges against disclosure of your confidences to L Dee Shipman. Subject to said objection and without waiving same, Plaintiff admits this 136: There are no privileges against disclosure of your confidences to Sherry Shipman. Subject to said objection and without waiving same, Plaintiff admits this 137: Sherry Shipman is not your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this 138: Sherry Shipman never has been your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this 139: You have discussed the payments from the Denton County, Texas Treasury to lawyers you appointed in private divorces with David Moraine.

29 Subject to said objection and without waiving same, Plaintiff denies this RE UEST FOR ADMISSION NO. 140: David Moraine is not your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this 141 : David Moraine never has been your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this 142: You have discussed the payments to lawyers from the Denton County, Texas Treasury to lawyers you appointed in private divorces with Robert Eames. incomprehensible. Plaintiff objects to this request on the grounds that it 143: Robert Fames is not your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this 144: Robert Eames never has been your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this

30 145: You have discussed the payments to lawyers from the Denton County, Texas Treasury to lawyers you appointed in private divorces with C. Jane Thacker. Plaintiff objects to this request on the grounds that it incomprehensible. 146: C. Jane Thacker is not your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this RE UEST FOR ADMISSION NO. 147: C. Jane Thacker never has been your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this 148: You have discussed the payments to lawyers from the Denton County, Texas Treasury to lawyers you appointed in private divorces with David Bouschor. Plaintiff objects to this request on the grounds that it incomprehensible. 149: this lawsuit. David Bouschor is not your attorney in : Plaintiff objects to this request on the grounds that the response to Subject to said objection and without waiving same, Plaintiff admits this 150: David Bouschor never has been your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this

31 151 : You have discussed the payments to lawyers from the Denton County, Texas Treasury to 1awyers you appointed in private divorces with Duane Coker. Plaintiff objects to this request on the grounds that it incomprehensible. 152: Duane Coker is not your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this 153 attorney in this lawsuit. Duane Coker never has been your Subject to said objection and without waiving same, Plaintiff admits this 154: You have discussed the payments to lawyers from the Denton County, Texas Treasury for private cases with Darcy Loveless. 155: Darcy Loveless is not your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this 156: Darcy Loveless never has been your attorney in this lawsuit.

32 Subject to said objection and without waiving same, Plaintiff admits this 157: You have discussed the payments to lawyers from the Denton County, Texas Treasury to lawyers you appointed in private divorces with Curtis Loveless. : incomprehensible. Plaintiff objects to this request on the grounds that it 158: Curtis Loveless is not and your attorney in this lawsuit. incomprehensible. Plaintiff objects to this request on the grounds that it 159: Curtis Loveless never has been your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this 160: You have discussed the payments to lawyers from the Denton County, Texas Treasury to lawyers you appointed in private divorces with Brad Freeman. Plaintiff objects to this request on the grounds that it incomprehensible. 161: this lawsuit. Brad Freeman is not your attorney in Subject to said objection and without waiving same, Plaintiff admits this 162: Brad Freeman never has been your attorney in this lawsuit.

33 Subject to said objection and without waiving same, Plaintiff admits this req uest. 163: You have discussed the payments to lawyers from the Denton County, Texas Treasury to lawyers you appointed in private divorces with Stephen Reese. incomprehensible. Plaintiff objects to this request on the grounds that it 164: Stephen Reese is not your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this 165: Stephen Reese never has been your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this 166: You have discussed the payments to lawyers from the Denton County, Texas Treasury to lawyers you appointed in private divorces with S. Camile Milner. incomprehensible. Plaintiff objects to this request on the grounds that it 167: S. Camile Milner is not your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this

34 168: S. Camile Milner never has been your attorney in this lawsuit. : Plaintiff objects to this request on the grounds that the response to Subject to said objection and without waivihg same, Plaintiff admits this 169: You have discussed the payments to lawyers from the Denton County, Texas Treasury to lawyers you appointed in private divorces with Mary Horn. incomprehensible. Plaintiff objects to this request on the grounds that it 170: You have discussed the payments to lawyers from the Denton County, Texas Treasury to lawyers you appointed in private divorces with Gary Kollmeier. incomprehensible. Plaintiff objects to this request on the grounds that it 171 : Gary Kollmeier is not your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this 172: Gary Kollmeier never has been your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this 173: You have discussed the payments to lawyers from the Denton County, Texas Treasury to lawyers you appointed in private divorces with Bruce Isaacks. incomprehensible. Plaintiff objects to this request on the grounds that it

35 174: Bruce Isaacks is not your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this 175: Bruce Isaacks never has been your attorney in this lawsuit. Subject to said objection and without waiving same, Plaintiff admits this 176: Bruce Isaacks had a bad reputation during his term of offce. Deny 177: Bruce Isaacks has a good reputation. Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request' s subject matter to 178: Bruce Isaacks had a good reputation during his term of offce. : Admit 179: Bruce Isaacks reputation from libel and slander during his term of office. : Admit had damaged 180: Bruce Isaacks suffered no damage to his reputation during his term of offce. Deny 181 : Bruce Isaacks sued New Times, Inc. for libel.

36 Plaintiff cannot admit or deny this request because she does not have suffcient information or knowledge of the request's subject matter to 182 : Bruce Isaacks claimed New Times, Inc. subjected him to ridicule. : Plaintiff cannot admit or deny this request because she does not have suffcient information or knowledge of the request's subject matter to 183: Bruce Isaacks claimed to have suffered damage to his reputation as a result of an article published by New Times, Inc. Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request' s subject matter to 184: Bruce Isaacks reputation was severely injured by the article published by New Times, Inc. Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request's subject matter to 185: Bruce Isaacks never recovered damages to his reputation following the article published by New Times, Inc. Plaintiff cannot admit or deny this request because she does not have suffcient information or knowledge of the request's subject matter to 186: Bruce Isaacks told you his reputation was badly damaged by the New Times, Inc. article. Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request'$ subject matter to 187: Bruce Isaacks told others his reputation was severely injured by the New Times, Inc. article. Plaintiff cannot admit or deny this request because she does not have suffcient information or knowledge of the request's subject matter to

37 188: The article published by New Times Inc. injured the reputation of Bruce Isaacks far more than any other event from that time. Plaintiff objects to this request on the grounds that it incomprehensible. Subject to said objection and without waiving same, Plaintiff cannot admit or deny this request because she does not have suffcient information or knowledge of the request's subject matter to 189: The article published by New Times Inc. caused Bruce Isaacks severe mental anguish. Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request's subject matter to 190: The article published by New Times Inc. caused Bruce Isaacks severe emotional anguish. : Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request' s subject matter to 191 : The article published by New Times Inc. caused Bruce Isaacks severe damage from which he has never recovered. Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request's subject matter to 192: The article published by New Times Inc. was protected by the First Amendment to the United States Constitution. Plaintiff cannot admit or deny this request because she does not have suffcient information or knowledge of the request' s subject matter to 193: Wiliam Trantham does not publish a newspaper. : Plaintiff cannot admit or deny this request because she does not have suffcient information or knowledge of the request's subject matter to

38 194: Willam Trantham has never published a newspaper. Plaintiff cannot admit or deny this request because she does not have suffcient information or knowledge of the request's subject matter to 195: Wiliam Trantham does not maintain a website. Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request's subject matter to 196: Wiliam Trantham has never maintained a website. Plaintiff cannot admit or deny this request because she does not have suffcient information or knowledge of the request's subject matter to 197: Willam Trantham did not say Bruce Isaacks is corrupt. Deny RE UEST FOR ADMISSION NO. 198: The article complained about in the News Connection the basis of this lawsuit quotes Willam Trantham. : Admit 199: The article complained about in the News Connection the basis of this lawsuit does not quote Willam Trantham. Deny 200: Trantham said in the News Connection: He claimed that Judge Isaacks appointed attorneys to represent children of divorced couples, charging the legal fees to the county.' Plaintiff objects to the request on the grounds that the article speaks for itself.

39 201 : Trantham did not say in the News Connection: ' He claimed that Judge Isaacks appointed attorneys to represent children of divorced couples, charging the legal fees to the county. Plaintiff objects to this request on the grounds that the article speaks for itself. 202: You do not know what Trantham said to any individual employed by the News Connection prior to the publication of the article the basis of this lawsuit. : Deny to the extent that statements made by Trantham were published by the News Connection. 203: You know what Trantham said to any individual employed by the News Connection prior to the publication of the article the basis of this lawsuit. : Admit to the extent that statements made by Trantham were published by News Connection. 204: Trantham knew the statements made to any individual employed by the News Connection were true. Deny 205: Trantham knew the statements made to any individual employed by the News Connection were not true. : Admit 206: Trantham believed the statements made to any individual employed by the News Connection were true. Deny 207: Trantham believed the statements made to any individual employed by the News Connection were not true. : Admit 208: At the time of the filing of this action you did not know what Trantham said to any individual employed by the News Connection.

40 Deny 209: Every statement in the News Connection article complained of by you was true. : Deny RE UEST FOR ADMIS ION NO. 210: Every statement in the News Connection article complained of by you was false. Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request' s subject matter to 211: Some of the statements in the News Connection article complained of by you were true. Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request' s subject matter to 212: Some of the statements contained in the News Connection article complained of by you were false. : Admit 213: You ordered a part to a divorce in your court to pay 100% of his disposable income to the mother of the child as child support. 214: Willam Trantham has run repeatedly for public office against Bruce Isaacks. Deny 215: Willam Trantham has never run for public offce against Bruce Isaacks. : Admit

41 216: You are easily terrorized. 217: You are not easily terrorized. 218: Wiliam Trantham has repeatedly run for public office against Vicki Isaacks. Deny 219: Wiliam Trantham has never run for office against Vicki Isaacks. : Admit 220: Willam Trantham has donated campaign funds to opponents of Bruce Isaacks. Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request's subject matter to 221 : Willam Trantham has always donated campaign funds to opponents of Bruce Isaacks. Plaintiff cannot admit or deny this request because she does not have sufficient information or knowledge of the request's subject matter to 222: Willam Trantham has donated campaign funds to opponents of Vicki Isaacks. Plaintiff cannot admit or deny this request because she does not have suffcient information or knowledge of the request's subject matter to