1960s Hanrahan Case Law in Texas T.R.A.P. Collin County Corruption Brief, Gallagher/Van-Kush v. Collin County, 05-20-00098-CV

Table of Contents
Introduction: Commanding Precedent… 1
Statement of Facts… 2
Statement of the Case … 4
Issues Presented… 4
A. Reopening and Merging Cases 4
1. Statute of Limitation and Religious Burden 4
2. Motion to Merge 5
B. Jurisdiction 6
1. Texas Jurisdiction 7
2. Federal Question Jurisdiction 7
3. Ultra Vires & Anti-Trust Law 8
C. Negligence/Noble Cause Corruption 9
D. Bill of Review 9
E. Conflict of Interest 10
F. Sovereign Immunity Waived and Destruction of Governmental Record 17
G. Bob Davis: Aggravated Perjury & Fraud on the Court 22
1. Fraud on the Court 24
2. Texas Penal Code S 37.03 Aggravated Perjury 24
H. Judge Cynthia Wheless (Illegal Sanctions, Void Order, Recusal) 25
I. Greg Abbott and Ken Paxton: Conflict of Interest 33
Summary of the Argument… 36
Argument… 37
Body… 40
A. History 40
B. Constitutional Challenge to a Statute & Mandamus 46
1. Attainder and Exemption 51
Request/Conclusion… 52
Root Case
In Re: Gallagher, WR-90,174-01
Case Law
Allen Glenn Thomas v. Texas Department of Criminal Justice-Institutional Division,

11-12-00121-CV (Tex. App. 2014) 32
Apresa v. Montfort Ins. Co., 932 S.W.2d 246 (Tex. App. 1996) 4
Belz v. Belz, 667 S.W.2d 240 (Tex. App. 1984) 9
Board of Medical Examiners v. Nzedu, 228 S.W.3d 264 (Tex. App. 2007) 8, 51
Bradt v. Sebek, 14 S.W.3d 756 (Tex. App. 2000) 9
Burwell v. Hobby Lobby, 573 US ___(2014) 7, 51
Cantwell v. Connecticut, 310 U.S. 296 (1940) 8, 51
Carpenter v. Carpenter, 93 S.E.2d 617 (N.C. 1956) 24
Christian v. State, 865 S.W.2d 198 (Tex. App. 1993); Rippo v. Baker, 580 U.S. ___ (2017) 2,
7, 8, 27, 39, 44, 45
Church of the Lukumi Babalu Aye, Inc. v. Hialeah, 508 U.S. 520 (1993) 4
City of Beaumont v. Bouillion, 896 S.W.2d 143 (Tex.1995) 7, 11, 23, 27, 36
City of Shreveport v.Taylor, 151 So. 638 (La. 1933) 8
Darlene C. Amrhein v.Attorney Lennie F. Bollinger, and Worminton & Bollinger Law Firm,
05-18-00567-CV (Tex. App.) 24
David Cary v. State, 460 S.W.3d 731 (Tex. App. - Dallas 2015) 10, 11
David Cary v. State, PD-0445-15 (Tex. Crim. App. 2016) 10, 11
Dent v. West Virginia, 129 U.S. 114 (1889) 7, 51
DOUGLAS v. AMERICAN TITLE COMPANY 01-04-00669-CV Court of Appeals of Texas,
Houston (1st Dist. 2006) 32
Earth Science Tech, Inc. v.Impact UA, Inc., 19-10118 (11th Cir. 2020) 8, 51
Ex Parte Price 7 41 S. W.2d 366 (1987) 39
Gallagher v. Dhillon 3:2018cv02801 (ND TX 2020) 23
Gallagher v. Collin County, et al, 05-20-00098-CV (Tx. App. 2020) 10
Gallagher v. Collin County, 417-01548-2017 (417 th District 2017) 9, 10, 37
Gilbert v. Tx. Mut. Insu. Co. No. 03-05-00787-CV (Tex. App. Dec. 19, 2008) 26, 31, 39
Glenn Hegar, Comptroller of Public Accountsv.Texas BLC, Inc., 01-18-00554-CV (Tex. App
2020) 2, 7, 8, 39, 44
Gonzales v. O Centro Espírita Beneficente União do Vegetal, 546 U.S. 418 (2006) 7, 51
Gonzales v. Raich, 545 U.S. 1 (2005) 7, 51
Hemp Industries Association v. DEA, Nos. 03-71366, 03-71693 (2004) 8, 51
Hilton v. Guyot, 159 US 113 (1895) 8
Hobson v. Wilson, 556 F. Supp. 1157 (D.D.C. 1982) 7, 9, 27, 36
In Re: Gallagher, 05-20-00128-CV (Tx. App. 2020) 10
In Re Cochener, 360 B.R. 542 (Bankr. S.D. Tex. 2007) 31
In Re Hms, 349 S.W.3d 250 (Tex. App. 2011) 3
In the Interest of K.A.R. No. 14-03-00970-CV Court of Appeals of Texas,Houston (14th Dist.
2005) 31, 39
In Re Patricia Potts and A.M.W.(A Child), 14-13-00562-CV (Tex. App. 2013) 32
In Re Perry, 60 S.W.3d 857 (Tex. 2001) 36
Jackson v. Ellis No. 07-13-00184-CV (Tex. App. Jun. 4, 2015) 31, 39
Jefferson County v. Sterk, 830 S.W.2d 260 (Tex. App. 1992) 9
John F. Buckner & Sons v. Allen, 272 S.W.2d 929 (Tex. App. 1954) 5
Johnson, Dietrick Lewis Sr., WR-83,532-01 (Tex. App. 2015) 11, 45
Juhl v. Airington, 936 S.W.2d 640 (Tex. 1997) 9
Karenev v. State, 258 S.W.3d 210 (Tex. App. 2008) 2
Koenig v. Purdue Pharma Co., 435 F. Supp. 2D 551 (N.D. Tex. 2006) 9
Lee v. WHISPERING OAKS HOME OWNERS'ASS'N, 797 F. Supp. 2D 740 (W.D. Tex. 2011)
9
Linder v. United States, 268 US 5 (1925) 7
Lucas v. United States, 757 S.W.2d 687 (Tex. 1988) 32
Luna v. COM. OF MASSACHUSETTS, 224 F. Supp. 2d 302 (D. Mass. 2002) 6
Lydia Tummel v. Robert Milane, 19-40148 (5th Cir. 2019) 9
Marbury v. Madison, 5 US 137 (1803) 8
Masterpiece Cakeshop, Ltd. v. Colorado Civil Rights Commission, 584 U.S. ___ (2018) 4
Mays v. Fifth Court of Appeals, 755 S.W.2d 78 (Tex. 1988) 36
McCann v. Michigan, 247 N.W.2d 521 (Mich. 1976) 8
Mellouli v. Lynch, 575 US ___(2015) 7, 51
Mercado v. Rockefeller,502 F.2d 666, 672 (2d Cir.1974) 46
Murakush Caliphate of Amexem Inc. v. New Jersey, 790 F. Supp. 2d 241 (D.N.J. 2011) 17
Near v. Minnesota, 283 U.S. 697 (1931) 31
Nguyen v. Intertex, Inc., 93 S.W.3d 288 (Tex. App. 2002) 9
NW Wholesale Stationers v. Pac. Stationary, 472 US 284 (1985) 9
Parker v. Parker, 916 So. 2d 926 (Fla. Dist. Ct. App. 2005) 24
Penick Corporation, Inc., Petitioner v. Drug Enforcement Administration, Respondent.chattem
Chemicals, Inc. and Mallinckrodt, Inc., Intervenors, 491 F.3d 483 (D.C. Cir. 2007) 47
Prestige Land Iran v. Hilti, 3:15-CV-3734-L (N.D. Tex. Jun. 14, 2018) 9
Rippo v. Baker, 580 U.S. ___ (2017) 7, 8, 39, 44, 45
Sharleen Wilson Allen v. Bryon Wilson, 06-15-00060-CV (Tex. Crim. App. 2015) 4
Spectator's Comm. Network, Inc. v. Colonial Country Club, et al., 253 F.3d 215 (5th Cir. 2001)
9
Stacy Cary v. State, 05-12- 01421-CR, 2014 WL 4261233 (Tex. App. - Dallas 2015) 9, 11
Stacy Cary v. State, PD-1341-14 (Tex. Crim. App. 2016) 10, 11
State of Texas v. Gallagher, Collin County Criminal Court, 0058313010 (2010-2015) 9
State v. Rhine, 297 S.W.3d 301 (Tex. Crim. App. 2009) 36
States v. Barboa,777 F.2d 1420, 1423 n. 3 (10th Cir.1985) 46
Strayhorn v. Ethical Society of Austin 110 S.W.3d 458 (Tex. App. 2003) 2, 7, 11, 23, 27, 36
The State Bar of Texas v. Gomez, 891 S.W.2d 243 (Tex. 1994) 7
Tilton v. Marshall, 925 S.W.2d 672 (Tex. 1996) 1
Tunica Web Advertising v. Tunica Casino Operators, 496 F.3d 403 (5th Cir. 2007) 8
United States of America, v. John F. Reynolds, 821 F.2d 427 (7th Cir. 1987) 7, 11, 23, 27, 36
United States v. ARTICLE OR DEVICE, ETC., 333 F. Supp. 357 (D.D.C. 1971) 8, 51
United States v. Bell, 70 F.3d 495, 496-97 (7th Cir.1995) 46
United States v. E. C. Knight Co., 156 U.S. 1 (1895) 8
United States v. Montilla, 870 F.2d 549, 552 (9th Cir.1989) 46
United States v. Morgan,230 F.3d 1067, 1071 (8th Cir. 2000) 46
United States v. Winter, 509 F.2d 975, 978 n. 8 (5th Cir.1975) 46
Untitled Texas Attorney General Opinion, GA-0384 (Tex. Att'y Gen. 2005) 1, 6, 8, 51
Untitled AG Opinion No. RQ-0367-JC (Tex. Att'y Gen. 2001) 8, 51
Wahad v. FBI, 994 F. Supp. 237 (S.D.N.Y. 1998) 5
Walker v. HUD 402 F.3d 532 (5th Cir. 2005) 5
Walker v. United States Department of Housing & Urban Development, 912 F.2d 819 (5th Cir.
1990) 5
Wooten v. Collin County, 4:18-cv-00380-ALM (EDTX 2018) 1, 9, 10, 11, 17, 23, 26, 27, 36,
37, 46
Willms v. Americas Tire Co., Inc., 190 S.W.3d 796 (Tex. App. 2006) 7
Written Law & US Constitution
U.S. Const. 1st Amendment (Religion and Establishment Clauses) 1, 53
18th Amendment 46
18 U.S. Code Sec 242 52
28 U.S. Code§ 1337 7
41 Stat. 305 (Pub. Law 66-66) 47
FRCvP Rule 902 4
Chapter 481 52
Chapter 11 31, 52
RICO 18 U.S. Code Sec 1962 53
Sec. 109.51 47
Sec. 110.001 48
Sec. 402.010 1
Sec. 481.002. 48
Sec. 481.062. 48
Sec. 481.0621. 48
Sec. 481.065. 48
Sec. 481.111. 48
Sec. 481.121. 48
Sec. 487.053. 48
Sec. 487.101 48
Sec. 487.103 48
Sec. 487.201 48
Tex. Civ. Prac. Rem. Code Sec 41 52
Texas Penal Code § 37.01 53
Texas Penal Code § 37.03 24, 53
Texas Penal Code § 37.10 (3) 17, 53
Tex. R. Civ. P. 270 5
Tex. R. Evid. 104 4
Tex. R. Evid. 1005 4
Title 5 Chpt 110 11, 52
TX House Bill 1325 51
TX ARTICLE 1, BILL OF RIGHTS

Sec. 6. 2, 52
Sec. 13 2, 52
Sec. 19 2, 52
Sec. 27 2, 52
Sec. 29 2, 52
Government Record and News
Applications To Become Registered Under the Controlled Substances Act To Manufacture

Marijuana To Supply Researchers in the United States, 81 FR 53846, 21 CFR 1301 8, 51
https://www.houstonchronicle.com/news/houston-texas/texas/article/Candidates-cite-politics-a
s-key-to-criminal-court-6797307.php 26
https://www.texasobserver.org/ken-paxton-wants-ultimate-home-field-advantage-in-felony-cas
e/ 18
https://www.votingfortom.com/about-tom/ 28
Police Report #20023116 24

5th COA
05-20-00128-CV
Request Oral Argument
Gallagher
v
Collin County, AG and State of Texas
Brief
Introduction: Commanding Precedent
A key component of this case is the FBI Investigation into Collin County District Attorney’s
Office and Greg Abbott, which according to the Judge Wooten false criminal case record, ended
August 28th, 2010 when they lied to the FBI. Wooten v. Collin County, 4:18-cv-00380-ALM
(EDTX 2018)
Tilton v. Marshall, 925 S.W.2d 672 (Tex. 1996)

Untitled Texas Attorney General Opinion, GA-0384 (Tex. Att'y Gen. 2005)
(CR), Gallagher v. City of Austin, Collin County, State of Texas, Texas Attorney General, 416-00049-
2020 (Collin County District Court, Judge Andrea Thompson), p351-378 show the Federal religious
exemption process which I am currently in the middle of
(RR), Lebo, Gallagher v. Collin County, State of Texas, Texas Attorney General, 416-00049-2020
(Collin County District Court, Judge Andrea Thompson), p35 l9-22
“It is difficult to determine with accuracy due to the amorphous nature of Gallagher's claims and his
shifting list of targeted defendants, but it appears that Ryan Gallagher has filed countless litigations
involving the alleged issues involving his beliefs about smoking Marijuana and his Religious Right to
do so."-(CR), Gallagher v. City of Austin, Collin County, State of Texas, Texas Attorney General, 416-
00049-2020 (Collin County District Court, Judge Andrea Thompson), p12; p14
"The Supreme Court has ruled that government has no authority to pass on the legitimacy of a
religious belief or to define permissible religious belief. Fowler v. Rhode Island, 345 U.S. 67 (1953);
United States v. Seeger, 380 U.S. 163 (1965)." -Internal Revenue Service (IRS), 1979 EO CPE, F.
CHURCHES AND OTHER RELIGIOUS ORGANIZATIONS
Sec. 402.010. LEGAL CHALLENGES TO CONSTITUTIONALITY OF STATE STATUTES

TEXAS CODE
ARTICLE 1, BILL OF RIGHTS
1
Sec. 6.
Sec. 13
Sec. 19
Sec. 27
Sec. 29
“MR. GALLAGHER: The testimony drives the Court to find as a fact that the unlawful and illegal
sanctions were imposed. Such sanctions were being carried out. Humble Oil Refining Company versus
Eighth Regional, WLB56 Northern District Of Texas 1944. The Power for contempt should only be
exercised with caution Ex Parte Arnold 503 S.W.2d 534 Texas Criminal Appeals 1974.” -(RR), Lebo,
Gallagher v. Collin County, State of Texas, Texas Attorney General, 416-00049-2020 (Collin County
District Court, Judge Andrea Thompson), p50 l10-24
see Christian v. State, 865 S.W.2d 198 (Tex. App. 1993); Rippo v. Baker, 580 U.S. ___ (2017) This
is a Rights case before it is a Vexatious Litigant Case, one issue is more important and is the foundation
of the other. Rights come first, it is your Bill. Glenn Hegar, Comptroller of Public Accountsv.Texas
BLC, Inc., 01-18-00554-CV (Tex. App 2020)
Freedom of Speech and Right to Criticize Public Officials

“ Unless the harassment statute is sufficiently clear to withstand constitutional scrutiny, no unlawful
harassment exists that would be excluded from First Amendment protection“ -Karenev v. State, 258
S.W.3d 210 (Tex. App. 2008)
The Laws of the State of Texas do not allow the State to Sanction and or Declare someone a Vexatious
Litigant because of their Religious Beliefs, or because of their Pursuit to have Religious Rights
Recognized in the Courts. But that is what has happened here. “Because this dispute presents us with a
constitutional issue, we review the trial court's decision de novo.” -Strayhorn v. Ethical Society of
Austin 110 S.W.3d 458 (Tex. App. 2003)
Statement of Facts
If I am making a False Accusation, prove it and charge me with Perjury.
2
A Major point to remember here is that the Name Change case, the Final hearing with Ashley Wysocki,
came before the Vexatious Litigant motion was even Docketed in Andrea Thompson’s court yet they
were talking about it in Ashley Wysocki’s court. This Vexatious Litigant motion came after they
thought they had defeated my Name change.
Collin County's motion to declare me a Vexatious Litigant was filed 01/08/20 and Notice of Hearing
was 01/09/20. The hearing was 01/23/2020. It was scheduled 30 minutes before a Sanctions hearing
that was already scheduled, and was initiated 2 day AFTER the 01/06/20 Name Change hearing where
they actually expected to lose, changing the styling of this case to El Sasha v. Collin County. 2 days
after that they filed the Vexatious Litigant Motion. The Sanctions hearing was for me to be in Jail for 6
months and until I dismissed cases against them, plus $500 per day. The Scope was changed to $26,000
in attorney's fees at the Hearing, no Notice, and I told the Judge on the record I was not ready to move
forward, but she then moved forward anyway. In Re Hms, 349 S.W.3d 250 (Tex. App. 2011)
The Name Change case is also a great example of an actual "adverse ruling. The Tex. Civ. Prac. Rem.
Code Chapter 22, Subchapter B, Sec. 11.054, (1), (A) says "finally determined adversely to the
Plaintiff". Simple Dismissal and request for a better complaint is not a "Final Determination" nor is it
"Adverse". The Name Change was "DENIED" not dismissed, Denied is Adverse.
This is clear, because (1), (C) says "Frivolous or Groundless", which my cases are not and have not
been labeled.
2020 (Collin County District Court, Judge Andrea Thompson), p170-205 (Original Motion for
Dismissal, Memorandum of Law filed in the Collin County Criminal case in 2015) This document
contains a good explination of the series of events underlying this case, it was used to create the 2017
filing. So this documemt is a fundamental document to this case. It has my Original Ministry
Certificate from 2009, from before I Established my own Religious Organization, the Shaivite Temple
FEIN#37-1949939, as well as an explaination of the 04/20/2010 Raid at 609 Riviera dr.
2020 (Collin County District Court, Judge Andrea Thompson), p207-232 (Open Records release from
Police regarding 04/20/2010 raid at 609 Rivera dr.
3
Statement of the Case
This case began in 2017, in Dec 2019 the Judge recused herself. Earlier in 2019 I filed the same case,
with new aggravating factors fro new events caused by the State, in Austin. It was Transferred to Collin
County, now it is here.
"Mr: Davis: But, to cut to the chase on this, we are asking that the case be transferred to Collin
County. The State and the Attorney General's Office agreed…"-(RR) DuBois, Gallagher v. City of
Austin, Collin County, State of Texas, Texas Attorney General, D-1-GN-19-004716 (Travis County
District Court, Judge Maya Guerra Gamble), p15 l24-25; p16- l1 This can be found in the Supplement
to Objection to Vexatious Litigant motion by county (CR5), Gallagher v. City of Austin, Collin County,
State of Texas, Texas Attorney General, 416-00049-2020 (Collin County District Court, Judge Andrea
Thompson), p243-265
Tex. R. Evid. 104; Tex. R. Evid. 1005; FRCvP Rule 902. Evidence That Is Self-
Authenticating
Issues Presented
A. Rule 270 Reopening and Merging Cases & Statute of

Limitation
(1) Statute of Limitations and Burden on Religion
As can be seen in the "Direct Examination" and General Filings in this case, Bob Davis seems to think
that this case will be lost by myself:
1. Because he doesn't like my Religion
2. Because Statute of limitations is up in his mind
3. Because of Sovereign Immunity
This brief shows the fanciful nature of those thoughts. Firstly, because Statute of Limitations don't
actually even start until the last date of injury, so the Statute of Limitations has yet to start running, let
alone being up. Sovereign Immunity is waived by the State in Religious suits, and the fact that he
openly doesn't like my Religion simply shows that the Government is hostile towards my Religion and
is not in his favor at all. Sharleen Wilson Allen v. Bryon Wilson, 06-15-00060-CV (Tex. Crim. App.
2015); Masterpiece Cakeshop, Ltd. v. Colorado Civil Rights Commission, 584 U.S. ___ (2018);
Church of the Lukumi Babalu Aye, Inc. v. Hialeah, 508 U.S. 520 (1993); Apresa v. Montfort Ins.
Co., 932 S.W.2d 246 (Tex. App. 1996)
4
2020 (Collin County District Court, Judge Andrea Thompson), p12; p14
(2) Motion to Merge
Tex. R. Civ. P. 270

Walker v. HUD 402 F.3d 532 (5th Cir. 2005); Walker v. United States Department of Housing & Urba
Development, 912 F.2d 819 (5th Cir. 1990); Wahad v. FBI, 994 F. Supp. 237 (S.D.N.Y. 1998)
The entire foundation of the defenses case rests on Aggravated Perjury committed by Bob Davis, the
current proceedings and Dismissed State and Federal cases are the Aggravating Factor. The initial act
of Perjury was during an illegal Sanctions hearing in a court I never appeared in; Bob Davis lied to the
Court and said that I am a Prisoner requesting Marijuana, as if I was not there because I was a criminal
and in Jail and wanted Marijuana while I was there. Further, the Judge who issued those illegal
Sanctions has recused herself after being exposed for being an operational member of the Defense, her
orders must be reconsidered and vacated. John F. Buckner & Sons v. Allen, 272 S.W.2d 929 (Tex.
App. 1954); Iketha Saunders, Individually and A/N/F of Rob Saunders, Robert Saunders, III and
Robnashea Saunders v. Lakisha Lee and Shawna D. Dodd, 10-04-00211-CV (Tex. App. 2005)
(January 23, 2020; 9:23 a.m.)

THE COURT: 416-01458-2017, Ryan Gallagher versus Collin County; 416-00049-2020, Ryan
Gallagher versus City of Austin, Collin County, State of Texas, Texas AG.-(RR), Lebo, Gallagher v.
Collin County, State of Texas, Texas Attorney General, 416-00049-2020 (Collin County District Court,
Judge Andrea Thompson), p5 l2-5
(RR), Lebo, Gallagher v. Collin County, State of Texas, Texas Attorney General, 416-00049-2020 (Collin
County District Court, Judge Andrea Thompson), p5 l18-25; p6 l1-10
(Collin County District Court, Judge Andrea Thompson), p21-23
County District Court, Judge Andrea Thompson), p23 l7-19
County District Court, Judge Andrea Thompson), p31 l1-6
5
(RR) DuBois, Gallagher v. City of Austin, Collin County, State of Texas, Texas Attorney General, D-1-
GN-19-004716 (Travis County District Court, Judge Maya Guerra Gamble), p10 l7-18 This can be
found in the Supplement to Objection to Vexatious Litigant motion by county (CR5), Gallagher v. City
of Austin, Collin County, State of Texas, Texas Attorney General, 416-00049-2020 (Collin County
District Court, Judge Andrea Thompson), p243-265
GN-19-004716 (Travis County District Court, Judge Maya Guerra Gamble), p17 l9-25; p18 l1-4 This
can be found in the Supplement to Objection to Vexatious Litigant motion by county (CR5), Gallagher
v. City of Austin, Collin County, State of Texas, Texas Attorney General, 416-00049-2020 (Collin
County District Court, Judge Andrea Thompson), p243-265
B. Jurisdiction
Untitled Texas Attorney General Opinion, GA-0384 (Tex. Att'y Gen. 2005)
Luna v. COM. OF MASSACHUSETTS, 224 F. Supp. 2d 302 (D. Mass. 2002)
6
2020 (Collin County District Court, Judge Andrea Thompson), p15; p16; p17
United States of America, v. John F. Reynolds, 821 F.2d 427 (7th Cir. 1987); Hobson v. Wilson,
556 F. Supp. 1157 (D.D.C. 1982); Strayhorn v. Ethical Society, 110 S.W.3d 458 (Tex. App. 2003);
City of Beaumont v. Bouillion, 896 S.W.2d 143 (Tex.1995); Christian v. State, 865 S.W.2d 198
(Tex. App. 1993); Rippo v. Baker, 580 U.S. ___ (2017); Glenn Hegar, Comptroller of Public
Accountsv.Texas BLC, Inc., 01-18-00554-CV (Tex. App 2020);
In Texas there is a word for what is being done by the County, Civil Conspiracy. And as Civil
Conspiracy is a factor in this case, it must first be considered by the court before any other issues. The
Civil Conspiracy Laws in Texas exist solely in case Law, and are for any Conspiracy against Rights
whatsoever, even Conspiracy against someone's inheritance. But the Federal Law better Illuminates
Civil Conspiracy, which exists in Federal Statute, and is Conspiracy against Rights based on Religion,
Race, Ethnicity, Nationality, etc. So this case meets both State and Federal Standards of Civil
Conspiracy. The State Bar of Texas v. Gomez, 891 S.W.2d 243 (Tex. 1994); Willms v. Americas
Tire Co., Inc., 190 S.W.3d 796 (Tex. App. 2006)
(1) Texas Jurisdiction
City of Beaumont v. Bouillion, 896 S.W.2d 143 (Tex.1995)
(2) Federal Question Jurisdiction
28 U.S. Code§ 1337.Commerce and antitrust regulations; amount in controversy, costs
Gonzales v. O Centro Espírita Beneficente União do Vegetal, 546 U.S. 418 (2006); Gonzales v.
Raich, 545 U.S. 1 (2005) (affirming that Congress may regulate personal Marijuana use as Interstate
Trade); Burwell v. Hobby Lobby, 573 US ___(2014) (ACA held to be in Violation of Religious Right
to believe Fetuses have Souls); Mellouli v. Lynch, 575 US ___(2015) (A case using the Cocaine Tax
Law/Harrison Tax Act where the CSA is not definitive, showing the CSA is a generational member of a
family of Laws, and not some alien lifeform immune to Fundamental Law); Linder v. United States,
268 US 5 (1925) (Harrison Narcotics case Stating "direct control of Medical practice in the States is
beyond the power of the Federal Government"); Dent v. West Virginia, 129 U.S. 114 (1889)
7
(Attainder case, and first case to mandate State Licensed Medical Doctors, and State Medical Boards).
See also, Cantwell v. Connecticut, 310 U.S. 296 (1940); Board of Medical Examiners v. Nzedu, 228
S.W.3d 264 (Tex. App. 2007); Untitled AG Opinion No. RQ-0367-JC (Tex. Att'y Gen. 2001);
Untitled Texas Attorney General Opinion, GA-0289 (Tex. Att'y Gen. 2005); Untitled Texas
Attorney General Opinion, GA-0384 (Tex. Att'y Gen. 2005); Earth Science Tech, Inc. v.Impact
UA, Inc., 19-10118 (11th Cir. 2020); Applications To Become Registered Under the Controlled
Substances Act To Manufacture Marijuana To Supply Researchers in the United States, 81 FR
53846, 21 CFR 1301; Hemp Industries Association v. DEA, Nos. 03-71366, 03-71693 (2004);
United States v. ARTICLE OR DEVICE, ETC., 333 F. Supp. 357 (D.D.C. 1971)
"Congress may regulate it in its entirety. That a particular instance of carjacking may have a de
minimis effect on interstate commerce is of no consequence" -Lopez, 514 U.S. at 558, 115 S. Ct. 1624
(citing Maryland v. Wirtz,392 U.S. 183, 197 n. 27, 88 S. Ct. 2017, 20 L. Ed. 2d 1020 (1968)). See also
United States v. Lopez, 514 U.S. 549, 115 S. Ct. 1624, 131 L. Ed. 2d 626 (1995); United States v.
Morrison,529 U.S. 598, 120 S. Ct. 1740, 146 L. Ed. 2d 658 (2000); and Jones v. United States, 529
U.S. 848, 120 S. Ct. 1904, 146 L. Ed. 2d 902 (2000); United States v. Rivera-Figueroa,149 F.3d 1, 3-4
(1st Cir.1998); United States v. Cobb,144 F.3d 319, 321 (4th Cir.1998); United States v. Romero, 122
F.3d 1334, 1339 (10th Cir. 1997); United States v. McHenry, 97 F.3d 125, 126-27 (6th Cir.1996);
United States v. Coleman, 78 F.3d 154, 157-60 (5th Cir. 1996); United States v. Hutchinson, 75 F.3d
626, 627 (11th Cir.1996); United States v. Bishop, 66 F.3d 569, 576-83 (3d Cir.1995); United States v.
Robinson,62 F.3d 234, 236 (8th Cir.1995); United States v. Oliver,60 F.3d 547, 549-50 (9th Cir. 1995).
(3) Ultra Vires & Anti-Trust Law
Constitutional Challenges to Government actions are not new, otherwise there would be no purpose in
having a Constitution. Ultra Vires is Latin, meaning "beyond the powers." Christian v. State, 865
S.W.2d 198 (Tex. App. 1993); Rippo v. Baker, 580 U.S. ___ (2017) This is a Rights case before it is a
Vexatious Litigant Case, one issue is more important and is the foundation of the other. Rights come
first, it is your Bill. Glenn Hegar, Comptroller of Public Accountsv.Texas BLC, Inc., 01-18-00554-
CV (Tex. App 2020)
"No law has any effect, of its own force, beyond the limits of the Sovereignty from which its authority is
derived" -Hilton v. Guyot, 159 US 113 (1895); Marbury v. Madison, 5 US 137 (1803); McCann v.
Michigan, 247 N.W.2d 521 (Mich. 1976); City of Shreveport v.Taylor, 151 So. 638 (La. 1933)
A great example of Ultra Vires acts are those where Governments create Monopolies, or Trusts. Though
Ultra Vires relates to Rule 5.1 historically, but is now primarily cited in Private Corporate Contract
Law, Ultra Vires and Rule 5.1 directly connect when the Government engages in an Ultra Vires contract
forming a Monopoly. Tunica Web Advertising v. Tunica Casino Operators, 496 F.3d 403 (5th Cir.
2007) (Section 1 of the Sherman Act)
A Monopoly is not a Monopoly if they happen naturally, with no Government Contract.United States
v. E. C. Knight Co., 156 U.S. 1 (1895)
8
Trust Defined:
"1. Engaged in Conspiracy
2. That restrained trade;
3. In a particular market" -Spectator's Comm. Network, Inc. v. Colonial Country Club, et al., 253
F.3d 215 (5th Cir. 2001); NW Wholesale Stationers v. Pac. Stationary, 472 US 284 (1985)
C. Negligence/Noble Cause Corruption

Judge's are Represented by the County so the County may be subject to suit for their actions. This
section is Evidence of and case law regarding Negligence and corruption. Jefferson County v. Sterk,
830 S.W.2d 260 (Tex. App. 1992); Juhl v. Airington, 936 S.W.2d 640 (Tex. 1997); Lydia
Tummel v. Robert Milane, 19-40148 (5th Cir. 2019); Bradt v. Sebek, 14 S.W.3d
756 (Tex. App. 2000); Agar Corp., Inc. v. Electro Circuits Int'l, LLC, 580 S.W.3d 136 (Tex. 2019);
Belz v. Belz, 667 S.W.2d 240 (Tex. App. 1984); Koenig v. Purdue Pharma Co., 435 F. Supp. 2d
551 (N.D. Tex. 2006); Lee v. WHISPERING OAKS HOME OWNERS'ASS'N, 797 F. Supp. 2d
740 (W.D. Tex. 2011); Hobson v. Wilson, 556 F. Supp. 1157 (D.D.C. 1982)
“Defendants John Roach, Sr., Christopher Defendant Milner, Gregory Abbott, and herein. Defendant
White (hereinafter the “Individual Defendants”) reached an agreement amongst themselves to
wrongfully arrest and prosecute Plaintiff for false and legally untenable claims” -Wooten v. Collin
County, 4:18-cv-00380-ALM (EDTX 2018)
D. Bill of Review
State of Texas v. Gallagher, Collin County Criminal Court, 0058313010 (2010-2015)
Gallagher v. Collin County, 417-01548-2017 (417th District 2017)
Prestige Land Iran v. Hilti, 3:15-CV-3734-L (N.D. Tex. Jun. 14, 2018); Alexander v. Hagedorn,
148 Tex. 565, 226 S.W.2d 996, 998 (1950); Nguyen v. Intertex, Inc., 93 S.W.3d 288 (Tex. App.
2002); Stacy Cary v. State, 05-12- 01421-CR, 2014 WL 4261233 (Tex. App. - Dallas 2015); David
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Cary v. State, 460 S.W.3d 731 (Tex. App. - Dallas 2015); David Cary v. State, PD-0445-15 (Tex.
Crim. App. 2016); Stacy Cary v. State, PD-1341-14 (Tex. Crim. App. 2016)
E. Conflict of Interest
Ashley Wysocki in the Dallas Court In Re: Gallagher, 05-20-00128-CV (Tx. App. 2020) married to
O’Neil Wysocki Law Firm who helped to elect Andrea Thompson and in the Name change case In Re:
Gallagher, 05-20-00128-CV (Tx. App. 2020) the Representative who appeared, on no legal grounds,
stated as their Primary argument that they did not want to “Start over with the Vexatious litigant
process”, a case taken by Andrea Thompson later that month, see Gallagher v. Collin County, et al,
05-20-00098-CV (Tx. App. 2020); Gallagher v. Collin County, 417-01548-2017 (417th District
2017); Wooten v. Collin County, 4:18-cv-00380-ALM (EDTX 2018), which was added as a late
tactic when Bob Davis realized his Motion for Contempt including an indefinite jail sentence and $500
per day fee would not be upheld after Cynthia Wheless recused herself, see Gallagher v. Collin
County, 417-01548-2017 (417th District 2017) Phi Delta Phi. This is why Andrea Thompson says it is
an issue for appeal, she does not want to rock the boat because they do not want to ”Start over” see
Gallagher v. Collin County, et al, 05-20-00098-CV (Tx. App. 2020)
This Case filed in the Texas Courts, and involving the Texas Attorney General is more of a Personal
case than it seems to be on its Face.
My Father is Robert Scott Gallagher, who is associated with PrintingYourNameOnIt and Executive
Press, as Co-Owner of these Companies being merged into Executive Press) as well as a Former
Member of the YMCA Board after our years in Indian Guides and Tae Kwon Do with the Valazquezes,
and also in a friendly relationship with the recent Former Mayor and other Parents of kids from my
School. I went to School with Chelsea Loughmiller, and she used to come over to our house, this is the
Daughter of the Former Mayor.
My Stepmom, Wendy Gallagher, was even given the role of Operating the McKinney Visitors Center,
which is Basically the Collin County Visitor Center, and my Parents have been to Ken Paxton
Campaign events, as he was previously the DA in our Town.
So as the Plaintiff, I am much more Closely tied to the Texas Attorney General than your average
Plaintiff, and anyone associated with me or the Attorney General, or Collin County, and who would
Benefit from this Case, should recuse themselves.
And it may be best for these Cases to be tried in more Neutral Counties, who are not directly effected
by the Relationships in this Case.
Cynthia Wheless Recusal because of Human Rights complaint cite # Gallagher v. Collin County, 417-
01548-2017 (417th District 2017) and City CJC Misconduct Case # Wooten v. Collin County, 4:18-
cv-00380-ALM (EDTX 2018) Christine Nowak Federal Case # cite lines from the Nowak R&R with
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Dates that it was written and ordered by the Judge later Greg Abbott then appoints Nowak’s husband
within 1 month of Nowak R&R to replace Cynthia Wheless husband, Suzanne Wooten same Judge
Andrea Thompson Wooten v. Collin County, 4:18-cv-00380-ALM (EDTX 2018) who said this case
would be an appeals case and that is why the record needed to be clear
“At the time of the CCDAO’s and the OAG’s investigation and prosecution of Judge Wooten, Gregory
Abbott was the Attorney General of Texas… Defendant Abbott, the OAG, allowed his office and
staff, including Defendant White, to assist the CCDAO in the investigation into Judge Wooten…
Roach did not like this person (Judge Greg Willis). After that comment, Davis tried to backtrack and
told D.J. to forget that D.J. heard that comment … On June 24, 2010, the Collin County grand jury
(CCGJ) voted eight to three in favor of a 90-day extension to their six-month term. The CCGJ wanted
to hear additional findings in the Judge Wooten investigation. Collin County District Judge Ray
Wheless was presiding over the grand jury at that time. Judge Wheless denied the grand jury the 90-
day extension because he felt the Attorney General (OAG) prosecutor was working on behalf of the
CCDAO and not the OAG.
” -Wooten v. Collin County, 4:18-cv-00380-ALM (EDTX 2018).
What they fail to realize is that when this is properly adjudicated (which is what they are requesting be
delayed by the court when they request that proper decisions be withheld because they do not want to
start over) is that they will have to stop. They are in violation of Rights Title 5 Chpt 110 – Grievance
system, no 30 days they do not need to start over they need to stop.
Collin County has a long documented history of corruption. Wooten v. Collin County, 4:18-cv-00380-
ALM (EDTX 2018); Johnson, Dietrick Lewis Sr., WR-83,532-01 (Tex. App. 2015); Stacy Cary v.
State, 05-12- 01421-CR, 2014 WL 4261233 (Tex. App. - Dallas 2015); David Cary v. State, 460
S.W.3d 731 (Tex. App. - Dallas 2015); David Cary v. State, PD-0445-15 (Tex. Crim. App. 2016);
Stacy Cary v. State, PD-1341-14 (Tex. Crim. App. 2016)
This is a Civil Conspiracy and Public Corruption Case, and both Collin County and the State of Texas
are not claiming it is not happening, and they can not make that claim because it is clear. Bob is not
even arguing that he did not commit Aggravated Perjury. What they are claiming is that it is covered by
Sovereign Immunity, which while the Civil Conspiracy against rights itself is a Constitutional Issue to
be resolved before even considering the State's defense, there is the 2nd Issue of determining if
Sovereign Immunity covers the overt and covert actions taken to remove a Religious element from
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your community, and even a neighboring community, with the false assumption that I, the Religious
element, am a singular independent problem, and not the tip of an iceburg within the community.
Further, Ken Paxton already has 3 Felony Charges and is clearly fighting to remain free after
committing criminal acts. It is well known as "Team Paxton" in the media, this is not a secret. My
father and Stepmom, as well as both Wheless Judges and others, are members of Team Paxton and have
openly endorsed him and are involved in both the Collin County Republican Party and Mckinney
Municipal Government. See, -United States of America, v. John F. Reynolds, 821 F.2d 427 (7th Cir.
1987); Hobson v. Wilson, 556 F. Supp. 1157 (D.D.C. 1982); Strayhorn v. Ethical Society, 110
S.W.3d 458 (Tex. App. 2003); City of Beaumont v. Bouillion, 896 S.W.2d 143 (Tex.1995)
Judge Ashley Wysocki is involved in that it seems as if Bob Davis had a massive influence on my
Name Change case, which I assume is part of the $26,000 and why the name change was denied. He
seems to have "Enforced Sanctions" by communicating with her office.
Judge Andrea Thompson replaced Cynthia Wheless and seemed to think that all of these are issues for
appeal, but also seems to have been Influenced by Bob Davis after Cynthia Wheless was recused. She
is also a Collin County Judge, associated with Ashley Wysocki through the O'Neil Wysocki Lawfirm.
Andrea Thompson did not hold me in Contempt, and she Enforced the Sanctions to award Bob David
$26,000 for what is now a Grand Total of 4/5 hearings I have ever been to in the US, the first one being
the 2017 Sanctions hearing I was not present for, 2nd the Associate Judge Name change hearing, then
Austin in the Original filing of this case, 2nd Name change hearing, then Jan 23rd, 2020. She also
wrote new Sanctions, but did not hold me in Contempt. All of this 17 days after Bob Davis sent
someone to my Name change hearing to tell Ashley Wysocki that they were soon filing a Motion to
Declare me a Vexatious Litigant.
Judge Ashley Wysocki and Judge Andrea Thompson do not even work in the same county here are
pictures showing that 2 of my judges in different counties are friends this is clearly a conflict
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13
14
15
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F. Sovereign Immunity Waived and Destruction of

Governmental Record
Murakush Caliphate of Amexem Inc. v. New Jersey, 790 F. Supp. 2d 241 (D.N.J. 2011)
Texas Penal Code § 37.10 (3) intentionally destroys, conceals, removes, or otherwise impairs the
verity, legibility, or availability of a governmental record;
“Q. Do you know the concept of "governmental sovereign immunity" that the County has?
A. No, not under Rule -- Title 5, Chapter 110 you guys have waived your sovereign immunity The State
has waived sovereign immunity for both municipalities and the State under Title 5, Chapter 110.
Q. So your allegations about --
A. Any judicial order, action, decision, ordinance, rule, law, anything is subject to that.
Q. So you dispute and you don't think that the County would have immunity for any claims about --
A. No.
Q. Let me finish my question, please, sir.
A. Sorry.
Q. -- about removing, as you allege, documents in a court file?
A. What do you mean "removing documents"?
Q. Okay. You have made an assertion that there was a felony. I did --
A. Yes.
Q. -- not see anything in any official record in Collin County that you've ever been charged with a
felony.“ -(RR), Lebo, Gallagher v. Collin County, State of Texas, Texas Attorney General, 416-00049-
2020 (Collin County District Court, Judge Andrea Thompson), p23 l20-25; p24 l1-16
Texas Penal Code § 37.10 (3) intentionally destroys, conceals, removes, or otherwise impairs the
verity, legibility, or availability of a governmental record;
These same people in fact tried to charge Judge Wooten with doing this
Plaintiff, Suzanne H. Wooten, was wrongfully arrested, charged, and convicted of multiple contrived
counts of Bribery, Conspiracy to Commit Engaging in Organized Criminal Activity, Money
Laundering, and Tampering with a Governmental Record, based on false and legally untenable
allegations. -Wooten v. Collin County, 4:18-cv-00380-ALM (EDTX 2018)
17
Ken Paxton was booked into the same jail 1 week before I was when I came back to Texas
This is “Team Paxton”

Ken Paxton Wants ‘Ultimate Home Field Advantage’ in Felony Case
https://www.texasobserver.org/ken-paxton-wants-ultimate-home-field-advantage-in-felony-case/
18
These are the records they have removed
19
20
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G. Bob Davis: Aggravated Perjury & Fraud on the Court

(Collin County District Court, Judge Andrea Thompson), p9 l10-25; p10 l1-25
The Collin County Records department became involved after my 40 days in Collin County Jail, which
resulted in a Dismissal of the Case in 2015. I requested records of my Correspondences with the
Programs Director. At some point after a year or more of being told by Records Staff that they didn't
have it, Jail Leutenants and finally an IT person in the jail, I did receive records, but became Homeless
soon after and lost them. When I requested them again Bob Davis took over, which was my first ever
email contact with him. He contacted the TX AG about my Open Records request. The records
department issue, to get Evidence to file this case, is where the Bob Davis issue started.
Bob Davis is the most Culpable, and clearly implicated in the Civil Conspiracy against Rights. This is
similar to if this were Officers of the County and one Officer was paid by the County, and became over-
engaged in a Civil Suit to the point of Corruption. He lists his fees for "Enforcing Sanctions" at
$26,000. I am not sure who in the County charged him with the task of doing this, but he is a Private
attorney with a Private Law Firm off LBJ and 75 right down the road (Dallas, Richardson?), I believe I
read that he has been a Prosecutor in Dallas, and he was appointed to my case by someone in Collin
County. He clearly seems to be stalking me across Texas, probably speaking to Judges and Clerks, and
other Court Employees, a cross Texas and likely in Colorado. He seems to be the most overtly active
participant. It is also likely that Bob Davis involved himself in my ND TX cases, possibly from the
beginning, but a Key change in my ND TX cases, (after a case against the DEA was filed in March
2017 but left open until over 1 year later, after the Nov 2017 Sanctions Agreement between Bob Davis
and Cynthia Wheless). In late 2018 early 2019, a Case was ignored by the ND TX for over a year again
then when I filed about new things my cases were no longer randomly assigned, but all assigned to
Judge Godbey, a Felony Drug Judge, and all dismissed. It is likely that this is when Bob Davis became
heavily involved. He may also be involved in influencing various Federal Court and Federal Agency
decisions, under the guise of "Sanctions Enforcement". Sanctions do not make me an Enemy of the
State, and these Sanctions aren't even valid in the first place. Collin County could technically use the
22
part of Rule 11 that says "cases 2 years without service" but they are not, because it is Bob Davis' job to
make sure no one gets served in my cases. It's not as if I am Vexatiously filing cases just to say I filed
them, Bob Davis is going around making that happen, and asking me to pay for it. NOTE: I began this
brief in April and shared it publicly and with the County and Bob, he then exposed himself by filing in
a Federal Court case not regarding the County Gallagher v. Dhillon 3:2018cv02801 (ND TX 2020)
around May 26th, 2020 showing that he is in fact operating outside the pervue of the Sanctions which
only mention actions against the County and he is no longer “Enforcing Sanctions” (and that is being
generous assuming the Sanctions weren’t based on Perjury committed by Bob, which they are) and is
likely the person responsible behind each and every one of the State and Federal Dismissals and
Sanctions orders. United States of America, v. John F. Reynolds, 821 F.2d 427 (7th Cir. 1987);
Hobson v. Wilson, 556 F. Supp. 1157 (D.D.C. 1982); Strayhorn v. Ethical Society, 110 S.W.3d 458
(Tex. App. 2003); Wooten v. Collin County, 4:18-cv-00380-ALM (EDTX 2018); City of Beaumont
v. Bouillion, 896 S.W.2d 143 (Tex.1995)
“MR. DAVIS: Based on that and my hourly rate, there was the total amount of $26,220.“ -(RR), Lebo,
Gallagher v. Collin County, State of Texas, Texas Attorney General, 416-00049-2020 (Collin County
District Court, Judge Andrea Thompson), p46 l5-14
“And then it has on that my background checks, which state that I had a -- if you can see this here
(indicating), there are two charges at first on there. And then it says I have a felony and then it gets
removed so that I just have the misdemeanor. Here's the dismissed on the examining trial --
Q. Have you been smoking pot today?
A. No. Examining trial, not enough --
Q. Are you sure?
A. -- probable cause --
THE COURT: Sir.
Q. (BY MR. DAVIS) If you'd step back, you smell like marijuana to me.
A. -- tamper and fabricating with evidence --
THE COURT: Mr. Gallagher.
A. -- not enough probable cause, dismissed.
THE COURT: Mr. Gallagher, have you used marijuana today?
MR. GALLAGHER: No.
MR. DAVIS: Yesterday?
MR. GALLAGHER: Yes, as part of my religion.” -(RR), Lebo, Gallagher v. Collin County, State of
Texas, Texas Attorney General, 416-00049-2020 (Collin County District Court, Judge Andrea
Thompson), p25 l2-22
Andrew Hatch is the Collin County Officer who took my Criminal Complaint against Bob Davis in Feb
2020, he was able to within a day or 2 gain access to my Collin County Jail Greivence system Records.
I assume this easy access to something that took them 2 years to retrieve for me, is because they very
probably contacted Bob Davis who would have happily "Enforced Sanctions" against me by getting
Andrew Hatch to disregard the Class 3 Felony of Aggrevated Perjury. Andrew Hatch closed it out
stating that Bob Davis' lie about me requesting Marijuana in jail was an "Opinion", not a lie, because I
mentioned my Religion in the Records. Not requested anything, but because I mentioned my Religion.
23
I am currently trying to get a copy of the record, but I don't have a $5 Bill to send them. Police Report
#20023116
(1) Fraud on the Court
Parker v. Parker, 916 So. 2d 926 (Fla. Dist. Ct. App. 2005); Carpenter v. Carpenter, 93 S.E.2d 617
(N.C. 1956); Darlene C. Amrhein v.Attorney Lennie F. Bollinger, and Worminton & Bollinger
Law Firm, 05-18-00567-CV (Tex. App.);
2020 (Collin County District Court, Judge Andrea Thompson), p270
2020 (Collin County District Court, Judge Andrea Thompson), p271
2020 (Collin County District Court, Judge Andrea Thompson), p277 278 279 280 281 284 292 297 300
303 310 316 319 322 329 332 343
(2)Texas Penal Code § 37.03. Aggravated Perjury
THE COURT: Okay. Sir, before we begin I need to ask if you swear or affirm that you're going to tell
the truth in these proceedings?
MR. GALLAGHER: Yes. Did he do the same?
THE COURT: He doesn't have to. He's an officer of the court. He's already done that pursuant to his
bar license, okay.
MR. GALLAGHER: Ok so he is under penalty of perjury right now?
THE COURT: Yes, he is. -(RR), Lebo, Gallagher v. Collin County, State of Texas, Texas Attorney
General, 416-00049-2020 (Collin County District Court, Judge Andrea Thompson), p12 l2-11
Here is a fairly detailed list of the Records (Collin County Jail Grievance System) that I am talking
about, which Bob Davis continues to lie about. I wrote this out with Pen and Paper in the jail then
24
transferred it to an email when I won the case and was released, so I had it available. I would like him
to prove that I have ever once requested to use Marijuana during the time of my Incarceration:
Request # 37595, I asked to be allowed to attend Religious Services, and they said I could go to the
Christian ones (even though I am not Christian) and I was ok with that.
Request # 42101, I was told by the Christian Priest that I was not allowed to attend Bible study because
I was not Christian, and I spoke with the Programs director, Jamie Taylor, in person and she apologized
and said that I could go to the Christian services.
Request # 42121, I point out that the Supreme Court has said that a Jail may have to incur expenses to
accommodate Religion, as I was told I couldn't go to Christian services, and that they didn't have Hindu
Religious texts, etc.
Request # 43154, I respond to the Program Director's Apology, as it came after the original request was
sent
Request # 44481, I tell them how they can get other Hindus printed versions of the Rig Veda, so that
they never have to tell anyone "We don't have your text" ever again (advice I am sure they ignored)
Request # 44803, I make the Staff aware that I will be spreading my faith, and having my own
Religious services, and bringing my Holy Book with my everywhere, no different than the Christians.
Request # 46056, I am told I can no longer bring my Religious Text with me places, and am told I can
only bring books approved by the Programs Director
Request # 46146, I am kicked out of the Inmate Worker Program because of my Religion, even after
getting approval from the Program's director in person to bring my Religious text, and Christians were
never not allowed during this whole time.
There are various problems with the Positions put forward by the County, first of all they claim that the
Lawsuit surrounding this was regarding Religious Marijuana in Jail, when in Reality it is about
Violations in jail of not being allowed to bring Religious Texts to Trustee Jobs, and being told by one of
the Preachers that in order to attend the Christian Church Services I had to be Christian, simply because
I knew more about the Bible than the other inmates there who were Christian and he did not like it. So I
would like Bob Davis to provide to the Court the Evidence that Marijuana was ever Requested. The
Order of Sanctions is Erroneous in that is says that I can not file the same Claims in State or Federal
Court against the County, yet never actually states a set of Claims that I have made. So the Sanctions to
not actually fully exist, as they do not have a mooring in Reality.
H. Judge Cynthia Wheless (Illegal Sanctions, Void Orders,

Recusal)
25
I was ordered to no longer file Claims for Religious Violations in Jail by Collin County, was by Judge
Cynthia Wheless. Her Husband is the Founder of the Drug Court in Collin County, and as being such
has a bias and is unable to see Marijuana as a Religious Sacrament (Sacred Food), rather than a "Drug"
which we are not using it as. She may be able to put the Fact that ruling for me in her Case could
destroy her Husbands Legacy out of her mind and rule fairly in my Case, but she did not disclose this
information, and accepted a Contempt Hearing Motion recently still with no mention of this, and I am
just learning all of this about the Whelesses and the Nowaks in September.
When she made her error I filed in the Federal Court, not understanding appeals processes at the time. I
also did not realize that Cynthia Wheless was the Judge, as I was unable to appear, and upon searching
the last name Wheless in Collin County found Ray Wheless, and filed the Federal Action against him,
and Collin County, and Ken Paxton. The Judge that took the Case was Christine Nowak. On September
10th, 2019, just about 2 months from this instant filing you are reading, she dismissed the Case against
Ken Paxton and Ray Wheless.
That same Month, Ray Wheless Retired as Collin County Judge, and appointed Christine Nowak's
Husband, Tom Nowak, to replace him in the 366th Court. So the Federal Magistrate who decided that
the District Court Judge's ruling was not Erroneous, without mentioning that her Husband was
replacing him (I mistakenly thought it was Ray Whelesses order) dismissed the Case and within the
same exact month, her Husband replaced the Defendant on the Bench. Who appoints Judges at this
time? Greg Abbott. Wooten v. Collin County, 4:18-cv-00380-ALM (EDTX 2018)
“Their target? Oldner's colleague on the Collin County District Court, Ray Wheless.
The two north Texas judges sit on either side of the Ken Paxton prosecution. Wheless, a long-time
friend and donor to the first-term current attorney general, has been critical of the grand jury process
that led to Paxton's indictment last July.” -https://www.houstonchronicle.com/news/houston-
texas/texas/article/Candidates-cite-politics-as-key-to-criminal-court-6797307.php
Gilbert v. Tx. Mut. Insu. Co. No. 03-05-00787-CV (Tex. App. Dec. 19, 2008)
MR. GALLAGHER: I mean, I object on the grounds that the judge has recused herself. She is
disqualified.
THE COURT: Do you have a legal objection to the exhibits being admitted?
MR. GALLAGHER: Yeah, this is all -- this is all the past. This is all stuff that doesn't -- that he did with
a judge that has declared herself disqualified now. -(RR), Lebo, Gallagher v. Collin County, State of
Judge Cynthia Wheless is also clearly Culpable in Civil Conspiracy. In the Original Sanctions order she
calls my claims against Ken Paxton "Gossip" and Evidence of Bad Faith, yet if you Google "Paxton
26
Wheless" they are clearly biased towards Ken Paxton, who now has a Triple Felony case in which he
signed a Confession Statement, and wrote the Law he broke. This is fact, not Gossip. His case has been
open 5 years now. But Ken Paxton became involved in 2016 or 2017 in this instant case before it was
ever assigned to Cynthia Wheless in my 2017 Original filing. Cynthia Wheless' husband created the
Drug Court in Collin County, which she never disclosed to me. I have since then retrieved copies of
both her Husband and her Financial Records. And the only big difference between my Indigency Form
I filed, is they have a house on it. I am Homeless, I am pretty sure Cynthia Wheless could File a
lawsuit, send you her Financial Record and move forward without payment of Court costs. Once
assigned to my case Cynthia took from March 2017 to November 2017 to have a hearing. March I was
living at Dallas Life and by May I had a FAFSA and was out of State going to school for around 8
months. I did not know about Efiling at this time. In Nov 2017 I was unable to appear, she proceeded to
move forward with Sanctions on a non-Present party on a nearly 1 year old case. Sanctions Bob Davis
has requested $26,000 for enforcing with no record of it being Enforced apart from 1 Federal Case in
the ED TX 2019 where Magistrate Christine Nowak wrote an R&R citing Bob's lie that I requested
Marijuana in jail, the case was dismissed within 1 week of Ray Wheless retiring and Tom Nowak,
Christine Nowak's husband was appointed to replace him on the 366th bench, Sept 2019. Upon my
own discovery of this through personal research, she was recused. Both Bob Davis and Cynthia
Wheless are Phi Delta Phi but failed to disclose this as a conflict to show they could work together
fairly. Judge Wheless has rightfully recused herself though and does deserve to be recognized for that
action, but may currently be fighting against me with Bob still and if that is the case she needs to be
recognized for that as well. Christian v. State, 865 S.W.2d 198 (Tex. App. 1993); Rippo v. Baker,
580 U.S. ___ (2017); United States of America, v. John F. Reynolds, 821 F.2d 427 (7th Cir. 1987);
Hobson v. Wilson, 556 F. Supp. 1157 (D.D.C. 1982); Strayhorn v. Ethical Society, 110 S.W.3d 458
(Tex. App. 2003); Wooten v. Collin County, 4:18-cv-00380-ALM (EDTX 2018); City of Beaumont
v. Bouillion, 896 S.W.2d 143 (Tex.1995)
Judge Christine Nowak enforced State Sanctions in Federal court on a case naming Ray Wheless as a
Defendant, by repeating Bob Davis' lie that I had requested Marijuana in jail, with no hearing, as the
Sanctions stated I could not file a Claim about Smoking Marijuana inside the Collin County Jail. The
only way to Enforce the Sanctions was to pretend I was again filing about Marijuana in jail, which I
never filed about in the first place. Her Husband, Tom Nowak, was then appointed to replace Ray
Wheless 1 week apart from the case against Ray Wheless being dismissed. She has yet to recuse herself
as Cynthia Wheless has. And both need to Vacate their Orders. Christian v. State, 865 S.W.2d 198
(Tex. App. 1993); Rippo v. Baker, 580 U.S. ___ (2017); United States of America, v. John F.
Reynolds, 821 F.2d 427 (7th Cir. 1987); Hobson v. Wilson, 556 F. Supp. 1157 (D.D.C. 1982);
Strayhorn v. Ethical Society, 110 S.W.3d 458 (Tex. App. 2003); Wooten v. Collin County, 4:18-cv-
00380-ALM (EDTX 2018); City of Beaumont v. Bouillion, 896 S.W.2d 143 (Tex.1995) Tom Nowak
says he comes from a former Soviet Republic and brings that experience to America as a service to
Justice and American Rights, but it seems he is either importing or integrating with Oppression and
Tyranny over Individual Liberty, Self-Determination and Religious Freedom.
Ray Wheless was the Administrative Judge for this County, he would clearly not be qualified, but he
also resigned. He was then replaced by Tom Nowak, who is Christine Nowaks' husband. The same
27
week Ray resigned and Tom took his place, Christine Nowak (a Federal Judge in the Eastern district,
and Tom's husband) was dismissing my case against the Whelesses, and Tom was given the 366th
bench as payment to the Nowaks for dismissing the case and Cynthia Wheless recused herself when I
brought this to her attention (she already knew, but she didn't know I knew until Dec, 2019, when she
recused herself). Tom Nowak is clearly also not qualified. The provision of "submitting with the
Administrative Judge" is unavailable for me, which is another issue. How can I file anything with an
Administrative Judge that is directly involved in the Defense? Tom Nowak says he comes from a
former Soviet Republic and brings that experience to America as a service to Justice and American
Rights, but it seems he is either importing or integrating with Oppression and Tyranny over Individual
Liberty, Self-Determination and Religious Freedom. He must feel right at home.
See https://www.votingfortom.com/about-tom/
28
29
Vexatious Litigant Designation and Rule 11
30
(1) Rule 11
2020 (Collin County District Court, Judge Andrea Thompson), p237-242
Right to criticize Government, firstly I spread no “Gossip” only public information, and it was all true
information about not Private Citizens, but my own Government.
Near v. Minnesota, 283 U.S. 697 (1931)
The underlying Sanctions and Orders in this case are all Void. This is due to the Illegal involvement of
the Whelesses and the Nowaks, 2 married Couples of Judges, Illegally involving themselves in this
case and on top of that the Sanctions were both Illegally implemented, that is regardless of the
corruption of the Whelesses and the Nowaks, and are based on Perjury, effecting Court cases, which
makes it Aggravated Perjury by Bob Davis in Cynthia Whelesses court 3 years before she recused
herself.
In the Interest of K.A.R. No. 14-03-00970-CV Court of Appeals of Texas,Houston (14th Dist.
2005); Jackson v. Ellis No. 07-13-00184-CV (Tex. App. Jun. 4, 2015); Gilbert v. Tx. Mut. Insu. Co.
No. 03-05-00787-CV (Tex. App. Dec. 19, 2008); Ex Parte Price 7 41 S. W.2d 366 (1987); In Re
Cochener, 360 B.R. 542 (Bankr. S.D. Tex. 2007)
I have now provided evidence of a false felony left on my record from 2010-2017 that I was never
informed of, and a dismissed misdemeanor case. Both are at the center of this lawsuit, as the Felony
is a false charge that went undismissed, and the misdemeanor is the case where my Religious Rights
were violated upon arrest and during the time I was in jail. That is the time Collin County claims I
requested Marijuana in jail, which is a false claim. Collin County is simply attacking my Religion.
(2) Vexatious Litigant Designation
31
2020 (Collin County District Court, Judge Andrea Thompson), p381-384
The Name Change case is a great example of an actual "adverse ruling. The Tex. Civ. Prac. Rem. Code
Chapter 22, Subchapter B, Sec. 11.054, (1), (A) says "finally determined adversely to the Plaintiff".
Simple Dismissal and request for a better complaint is not a "Final Determination" nor is it "Adverse".
The Name Change was "DENIED" not dismissed, Denied is Adverse.
This is clear, because (1), (C) says "Frivolous or Groundless", which my cases are not and have not
been labeled. In Re Patricia Potts and A.M.W.(A Child), 14-13-00562-CV (Tex. App. 2013);
DOUGLAS v. AMERICAN TITLE COMPANY 01-04-00669-CV Court of Appeals of Texas,
Houston (1st Dist. 2006); Allen Glenn Thomas v. Texas Department of Criminal Justice-
Institutional Division, 11-12-00121-CV (Tex. App. 2014); Lucas v. United States, 757 S.W.2d 687
(Tex. 1988)
2020 (Collin County District Court, Judge Andrea Thompson), p277 278 279 280 281 284 292 297 300
303 310 316 319 322 329 332 343
32
2020 (Collin County District Court, Judge Andrea Thompson), p19-168 (Shows that most cases were
dismissed without prejudice, and almost all dismissed without service, very few dismissed as Frivolous)
I. Greg Abbott and Ken Paxton: Conflict of Interest
33
34
35
Wooten v. Collin County, 4:18-cv-00380-ALM (EDTX 2018); Mays v. Fifth Court of Appeals, 755
S.W.2d 78 (Tex. 1988); In Re Perry, 60 S.W.3d 857 (Tex. 2001); State v. Rhine, 297 S.W.3d
301 (Tex. Crim. App. 2009)
Ken Paxton is involved in at least Negligence, but likely active Participation in the Conspiracy. Various
documents have been filed by the AG who was at first a Subject in the 2017 case, but is listed as a
Defendant in the 2019 filing because of his ongoing activity. And not only has he been involved in this
case, but for almost a year now I have been awaiting a response from the Secretary of State regarding
an AP-20x filing. The SoS originally accepted an AP-20x application, basically saying that because I
am Homeless my Orginization not a "Church" perse as in a Building. So I filed an AP-20x for
Organizations under 501(c)(3) or Charities, Lodges, etc. I filed this around July 2019 and filed suit in
Dallas County about the "Church" definition issue. They refused to respond referring me to Keeney at
the AG's office. The Dallas Court then ruled that Tax Cases must be brought in Austin, despite the
Religious nature, and I failed to appeal thinking I would need to file in Austin and I was living at the
Salvation Army. This was in November 2019, and the AG and SoS still refuse to grant Tax Exempt
Status. I also filed a sister case to the Instant case, against the AG and DPS in the Dallas District Court.
United States of America, v. John F. Reynolds, 821 F.2d 427 (7th Cir. 1987); Hobson v. Wilson,
556 F. Supp. 1157 (D.D.C. 1982); Strayhorn v. Ethical Society, 110 S.W.3d 458 (Tex. App. 2003);
Wooten v. Collin County, 4:18-cv-00380-ALM (EDTX 2018); City of Beaumont v. Bouillion, 896
S.W.2d 143 (Tex.1995)
Greg Abbott is involved on at least a Negligence level, but may be in on the Agreememt. He facilitated
the Payment between the Whelesses and the Nowaks, on behalf of Bob Davis, who now wants $26,000
for making that happen. Saying he is responsible. But Greg Abbott could also be a full participant,
given his history with the Collin County District Attorney's office (CCDAO). United States of
America, v. John F. Reynolds, 821 F.2d 427 (7th Cir. 1987); Hobson v. Wilson, 556 F. Supp. 1157
(D.D.C. 1982); Strayhorn v. Ethical Society, 110 S.W.3d 458 (Tex. App. 2003); Wooten v. Collin
County, 4:18-cv-00380-ALM (EDTX 2018); City of Beaumont v. Bouillion, 896 S.W.2d 143
(Tex.1995)
GN-19-004716 (Travis County District Court, Judge Maya Guerra Gamble), p5 l15-19; l24-25; p6 l1
This can be found in the Supplement to Objection to Vexatious Litigant motion by county (CR5),
Gallagher v. City of Austin, Collin County, State of Texas, Texas Attorney General, 416-00049-2020
(Collin County District Court, Judge Andrea Thompson), p243-265
Summary of the Argument

As can be seen in the "Direct Examination" and General Filings in this case, Bob Davis seems to think
that this case will be lost by myself:
36
1. Because he doesn't like my Religion
2. Because Statute of limitations is up in his mind
3. Because of Sovereign Immunity
Argument
Wooten v. Collin County, 4:18-cv-00380-ALM (EDTX 2018) Bob Davis lying about requesting
Marijuana in jail and then disputing the existence of the felony on my record which effected my ability
to rent apartments or get jobs for 7 years and was dismissed in examining trial with me never even
being made aware of it and never being convicted or tried for it cite 2 Collin County transcripts from
Jan 23rd and Austin Transcript and EDTX R&R Nowack Police Report # for Aggravated Perjury cite
cases where people have been convicted of it
Gallagher v. Collin County, 417-01548-2017 (417th District 2017)
Cynthia Wheless Sanction calling things rumors and bad faith with no evidence of bad faith
whatsoever and Contempt motion not upheld by Andrea Thompson
DIRECT EXAMINATION
BY MR. DAVIS:
Q. All right. Mr. Gallagher, I believe you've testified that your claim against Collin County arises from
an alleged arrest in 2010, correct?
A. Yes.
Q. Which would be far more than two years prior to filing the lawsuit, correct?
A. Well, it didn't end until 2017, as I just stated in the previous...
Q. When was the last time you were incarcerated in the Collin County jail?
A. 2015. 2016.
Q. And you would agree --
A. 2016.
Q. You would agree with me, sir, that that is well past two years prior to filing the most recent lawsuit?
A. Yes, this is -- as you say even, this is a continuum and this is something that happened and I didn't
know about until 2017 and filed the case in 2017, the same year that I found out about the felony that
was still on my record, which is connected to the exact same day back in 2010, which then goes
forward with all the other things that I didn't know was there though, the whole time.
Q. You understand in this motion the County has alleged that you will not prevail because of the
limitations; do you understand that, sir?
A. No, because that's false.
Q. Do you know what "statute of limitations" is?
A. Yes, I know what statute of limitations is.
Q. Do you know what the statute of limitations is in Texas for a tort?
A. Yes, it's two years unless you can prove that it's still happening.
Q. And all of the things that you've alleged occurred in 2010 and 2015, correct?
A. No, 2017.
Q. What happened in 2017?
37
A. I had a felony removed from my record that I never even knew was there from 2010.
Q. And that is an action that you included in your prior lawsuit filed in the 417th?
A. 2017.
Q. And you've already sued the County over that, haven't you?
A. That's what this is about today. We're here talking about the 01458 and 00079 -- or 49.
Q. My question, sir, is this allegation about the felony, which I dispute, but your belief that you had a
felony, all of those issues were previously raised in your earlier lawsuit against Collin County in the
417th District Court in --
A. It was not raised because they said it was about smoking marijuana in jail, so that is what that case
was about is what you guys say. That's what you're -- you guys claim that the case was about smoking
marijuana in jail. So, no, that is what was raised and not the issue that I'm talking about. And you guys
said I couldn't bring that up again, which is not the issue that we're talking about right now. -(RR),
Lebo, Gallagher v. Collin County, State of Texas, Texas Attorney General, 416-00049-2020 (Collin
And then it has on that my background checks, which state that I had a -- if you can see this here
(indicating), there are two charges at first on there. And then it says I have a felony and then it gets
removed so that I just have the misdemeanor. Here's the dismissed on the examining trial --
Q. Have you been smoking pot today?
A. No. Examining trial, not enough --
Q. Are you sure?
A. -- probable cause --
THE COURT: Sir.
Q. (BY MR. DAVIS) If you'd step back, you smell like marijuana to me.
A. -- tamper and fabricating with evidence --
THE COURT: Mr. Gallagher.
A. -- not enough probable cause, dismissed.
THE COURT: Mr. Gallagher, have you used marijuana today?
MR. GALLAGHER: No.
MR. DAVIS: Yesterday?
MR. GALLAGHER: Yes, as part of my religion. -(RR), Lebo, Gallagher v. Collin County, State of
"Mr. Gallagher: I never requested to be able to use Marijuana in jail. It's about my Religious Text
which was denied to me when I was doing work in the jail as a Trutee. And the Christians were allowed
to bring their Bibles, but they stopped letting me bring my Religious Text to my job. It had nothing to
do with Marijuana in jail. The possession of Marijuana stems from the criminal charge that he was
talking about that got dismissed whenever I came to Texas, State of Texas, and I filed a Religious
Defense, they dismissed the case and forced me out of jail because I was helping people with their
cases as a Jailhouse Lawyer. And they like made me leave and then they -- that case was dismissed
claiming that I finished probation when, as he said, I went to the State of Colorado and left, I never
finished probation. And so that case needs to be redisposed because it says I completed probation, that
is what the case states if you go look at it." -(RR) DuBois, Gallagher v. City of Austin, Collin County,
38
State of Texas, Texas Attorney General, D-1-GN-19-004716 (Travis County District Court, Judge Maya
Guerra Gamble), p17 l9-25; p18 l1-4 This can be found in the Supplement to Objection to Vexatious
Litigant motion by county (CR5), Gallagher v. City of Austin, Collin County, State of Texas, Texas
Attorney General, 416-00049-2020 (Collin County District Court, Judge Andrea Thompson), p243-265
Void Orders Christian v. State, 865 S.W.2d 198 (Tex. App. 1993); Rippo v. Baker, 580 U.S. ___
(2017) This is a Rights case before it is a Vexatious Litigant Case, one issue is more important and is
the foundation of the other. Rights come first, it is your Bill. -Glenn Hegar, Comptroller of Public
Accountsv.Texas BLC, Inc., 01-18-00554-CV (Tex. App 2020)
The underlying Sanctions and Orders in this case are all Void. This is due to the Illegal involvement of
the Whelesses and the Nowaks, 2 married Couples of Judges, Illegally involving themselves in this
case and on top of that the Sanctions were both Illegally implemented, that is regardless of the
corruption of the Whelesses and the Nowaks, and are based on Perjury, effecting Court cases, which
makes it Aggravated Perjury by Bob Davis in Cynthia Whelesses court 3 years before she recused
herself. In the Interest of K.A.R. No. 14-03-00970-CV Court of Appeals of Texas,Houston (14th
Dist. 2005); Jackson v. Ellis No. 07-13-00184-CV (Tex. App. Jun. 4, 2015); Gilbert v. Tx. Mut.
Insu. Co. No. 03-05-00787-CV (Tex. App. Dec. 19, 2008); Ex Parte Price 7 41 S. W.2d 366 (1987)
GN-19-004716 (Travis County District Court, Judge Maya Guerra Gamble), p17 l9-25; p18 l1-4 This
can be found in the Supplement to Objection to Vexatious Litigant motion by county (CR5), Gallagher
v. City of Austin, Collin County, State of Texas, Texas Attorney General, 416-00049-2020 (Collin
39
of Austin, Collin County, State of Texas, Texas Attorney General, 416-00049-2020 (Collin Cou
Body
A. History
0058313010
417-01458-2017
D-1-GN-19-004716
416-01458-2017
416-00049-2020
40
Affidavit of Religion
41
42
43
April 20, 2010, within the same time frame Judge Wooten was being viciously attacked by Collin
County, the Police raided my home. When they came to my home they knocked on the front door and I
was asleep on a couch watching TV in the backyard by the pool. My friend woke me up, and told me
there was Police at the door. I went inside and went upstairs, at which time they entered the backyard
stating in their report that they had seen me walking up stairs. They then arrested my friend in the
backyard, I came down the stairs and was arrested on the stairs. They then took us to the backyard
where we had books about religious sacraments which they directly asked us about and we had a
number of other sacred herbs which we talked to the about
We were then taken to jail, and were bailed out. My first attorney would not allow me to present a
Religious defense, I asked him to remove himself from my case and he wrote a nasty letter to the Judge
and he was replaced by Kerrie Walker, former Plano PD and corrupt DA who resigned. She forced me
to plea guilty.
7 years later I discover they tried to charge me with a Felony, Dismissed it, but never changed the
record to reflect it was dismissed.
This is in regards to Criminal Case# 0058313010 in the Collin County County Criminal Court and
Civil Case# 417-01458-2017 in the Collin County District Civil Court. First, in 0058313010 I was
arrested in my Home, with no Warrant in violation of my 4th Amendment Rights, and in Violation of
my 1st Amendment Religious Rights, as well as against my Texas Constitutional Rights of Religion
and Search. And a Motion to Dismiss was filed to this effect, but even though the Case was dismissed
the Judge refused to Acknowledge the Motion to Dismiss and its contents. But this is what the Motion
to Dismiss was about. Then the Case was dismissed, and instead of Redisposing the Case, the Judge
left it on my Record as if I had finished Probation, which I did not, I was not even in the State for
Probation. Then I sued because I was fired from a Job for a Felony they had put on my Record, and
instead of “Guilty” or “Not Guilty” or “Dismissed” it said “Released from Jail” and it affecting my
ability to rent and work for 7 years. I did get the County to delete that Case (not a Judge, some other
City Employee, her name was Deborah Ramirez or something, I can find it if I need to) so that case is
no longer on my Record. The Lawsuit also involved Religious Violations in the County Jail, such as the
Pastor there telling me I had to be Christian and Couldn’t be Hindu and kicking me out of Church on
Sunday for knowing too much about where everything is in the Bible and not being Christian.
Then I asked the Judge in Case# 0058313010 to redispose the Case, but he refused. I filed a Civil Case,
Case# 417-01458-2017 and they filed a hearing for when I was in Colorado, and did not read anything
Void Orders Christian v. State, 865 S.W.2d 198 (Tex. App. 1993); Rippo v. Baker, 580 U.S. ___
(2017) This is a Rights case before it is a Vexatious Litigant Case, one issue is more important and is
the foundation of the other. Rights come first, it is your Bill. Glenn Hegar, Comptroller of Public
Accountsv.Texas BLC, Inc., 01-18-00554-CV (Tex. App 2020)
I filed in response to the Defendants, and gave me Sanctions

because the County Requested Sanctions and I was not at the Hearing. Not based on Evidence, not
based on anything other than the Fact that I was not there. So they gave me Sanctions, and Dismissed
the Case, and that was my first Court Case ever. I am Pro Se, I am not an Attorney, and they forced me
to learn about the Courts and the Federal Courts, and since Austin Texas removed a Case on Mine to
44
Federal Court in 2015, I have learned a lot more. But when I was doing this County Case I was not
familiar with Federal filing deadlines, and Notices, and everything.
Request part 1:
So I request that the Court Correct the Lower Courts Legal Errors, in
a Writ of Mandamus or Writ of Error:
1. I request the Low Court be ordered to Redispose my Criminal Case to reflect the Dismissal
2. I request that the Sanctions be lifted, after a hearing to determine that they are Void
3. I request that my Civil Case be reopened and actually tried, not brushed under a rug
Guilty Plea
Johnson, Dietrick Lewis Sr., WR-83,532-01 (Tex. App. 2015)
In 2010, Kerrie Walker forced me to accept a guilty plea after another attorney would not let me present
a Religious defense and Kerrie did the same. I was 18, and had been arrested from the age of 14 for my
Religion, I did not know how to articulate a Religious defense myself and she forced me to sign papers
for probation and plea guilty. I then fled the State and was gone studying my Rights for 5 years, came
back in 2015 and the case was dismissed but the court refused to change the disposition. The
disposition says I was given probation, the Docket says Probation Revoked and Case Dismissed. Void
Orders Christian v. State, 865 S.W.2d 198 (Tex. App. 1993); Rippo v. Baker, 580 U.S. ___ (2017)
Further, while this was all happening, the County had secretly put a Felony on my record, none of my
attorneys told me about it, even the 3rd one in 2015, and it was dismissed on examining trial, but said
"Released from Jail".
2020 (Collin County District Court, Judge Andrea Thompson), p207-232 (Open Records release from
Police regarding 04/20/2010 raid at 609 Rivera dr.
“The CCDAO had ulterior malicious political motivations for prosecuting Judge Wooten. The CCDAO
wanted Judge Wooten off the bench because the CCDAO disagreed with Judge Wooten’s rulings in
criminal cases. This motivation is evident from a myriad of evidence including, a CCDAO internal
email and the redaction of incriminating statements before dissemination of that email as a response to
a public information request, the pressuring of witnesses, destruction of evidence, and the clear misuse
and abuse of the grand jury process. Additionally, it was widely known in the legal community that the
CCDAO had a Special Crimes Division headed by Defendant Milner who used heavy-handed tactics
and strategies to investigate, intimidate and often indict those who were his enemies. As detailed below,
numerous lawyers, elected officials and courthouse staffers were target by CCDAO during the two
terms former District Attorney Roach ran the CCDAO and employed Defendant Milner. The OAG
45
knowingly aided the CCDAO in accomplishing their goals by way of prosecuting Judge Wooten when it
was clear a crime had not occurred…” -Wooten v. Collin County, 4:18-cv-00380-ALM (EDTX 2018)
United States v. Morgan,230 F.3d 1067, 1071 (8th Cir.2000) (recognizing that a claim that a statute is
facially unconstitutional is a jurisdictional claim not waived by a guilty plea); United States v. Bell, 70
F.3d 495, 496-97 (7th Cir.1995) (challenge to constitutionality of statute of conviction is, in certain
circumstances, jurisdictional claim not waived by guilty plea)."); Bell, 70 F.3d at 496-97 (addressing
defendant's challenge to the constitutionality of the underlying statute after recognizing the principle
that such a challenge "is a jurisdictional claim which is not waived by the guilty plea"); United States
v. Montilla, 870 F.2d 549, 552 (9th Cir.1989) (stating that although the dividing line between
constitutional claims that are waived by a guilty plea and those that survive the plea is not "crystal-
clear," "[c]laims that `the applicable statute is unconstitutional or that the indictment fails to state an
offense' are jurisdictional claims not waived by the guilty plea" (quoting Broncheau, 597 F.2d at 1262
n. 1)), amended by907 F.2d 115 (9th Cir.1990); States v. Barboa,777 F.2d 1420, 1423 n. 3 (10th
Cir.1985) ("A plea of guilty ... does not bar a claim that the defendant may not constitutionally be
convicted in the first instance.... If [the defendant] ple[aded] guilty to something which was not a
crime, he is not now precluded from raising this jurisdictional defect, which goes `to the very power of
the State to bring the defendant into court to answer the charge brought against him.'" (quoting
Blackledge, 417 U.S. at 30, 94 S. Ct. 2098)); United States v. Winter, 509 F.2d 975, 978 n. 8 (5th
Cir.1975) (recognizing "that after entering ... a plea of guilty, a defendant may only appeal
jurisdictional defects in the proceeding below, such as ... the unconstitutionality of the statute
underlying the indictment"); Mercado v. Rockefeller,502 F.2d 666, 672 (2d Cir.1974) ("[I]t is clear
that [a] guilty plea waives only nonjurisdictional defects and does not waive the right to contest the
constitutionality of the statute that is the basis for a conviction." (second alteration in original)
(quotations and citation omitted))
B. Constitutional Challenge to a Statute & Mandamus
Prohibition of Alcohol in the United States in the 1920s was different than the Controlled Substances
Act in that Prohibition was added to the Constitution as the 18th Amendment, the Controlled
Substances Act was only written into Law. And the Constitution was Amended again with the 21st
Amendment to legalize Alcohol and give Regulation to the States. While Alcohol was prohibited under
a Constitutional Amendment, Alcohol was still legal for Religious and Medical use:
"...the manufacture, sale, or transportation of intoxicating liquors within, the importation thereof into, or
the exportation thereof from the United States and all territory subject to the jurisdiction thereof for
beverage purposes is hereby prohibited." -18th Amendment, Passed by Congress December 18,
1917. Ratified January 16, 1919
The Volstead Act
46
"Nothing in this title shall be held to apply to the manufacture, sale, transportation, importation ,
possession, or distribution of wine for sacramental purposes, or like religious rites, except section 6
(save as the same requires a permit to purchase) and section 10 hereof, and the provisions of this Act
prescribing penalties for the violation of either of said sections. No person to whom a permit may be
issued to manufacture, transport, import, or sell wines for sacramental purposes or like religious rites
shall sell, barter, exchange, or furnish any such to any person not a rabbi, minister of the gospel,
priest, or an officer duly authorized for the purpose by any church or congregation, nor to any such
except upon an application duly subscribed by him, which application, authenticated as regulations
may prescribe, shall be filed and preserved by the seller. The head of any conference or diocese or
other ecclesiastical jurisdiction may designate any rabbi, minister, or priest to supervise the
manufacture of wine to be used for the purposes and rites in this section mentioned, and the person
so designated may, in the discretion of the commissioner, be granted a permit to supervise such
manufacture."-41 Stat. 305 (Pub. Law 66-66)
There is a similar exemption in Texas State Law for Religious use of Alcohol:
TEXAS ALCOHOLIC BEVERAGE CODE

TITLE 4. REGULATORY AND PENAL PROVISIONS
CHAPTER 109. MISCELLANEOUS REGULATORY PROVISIONS
SUBCHAPTER D. OTHER MISCELLANEOUS PROVISIONS
Sec. 109.51. SACRAMENTAL WINE.
The DEA has Exemptions for Manufacturing and Importing Substances, as well as Importing Raw
Narcotic Material (RNM) such as Coca Leaves or Poppy Straw. Coca Leaves have been, and still are,
imported into America from Peru since Coca-Cola was made, at which time it was sold over the
counter with a Tax under the Harrison Narcotics Tax Act; Marijuana was similarly regulated under the
Marihuana Tax Act. When the UN Psychotropics Convention (1971) Treaty was impacted and
Ratified into U.S. Law through the Controlled Substances Act, the Substances became "Controlled"
instead of "Taxed" as they were previously, but they have never been banned. Even today Stepan Co.
Imports Raw Coca Leaf, then extracts it and sells the Cocaine to Mallinckrodt Pharmaceuticals for use
in eye surgeries, while the other byproduct extract is sold to Coca-Cola as a Flavoring. DEA Form 225
and RNM registration are similar, and here is the non-Religious Pharmaceutical Registration process.
Penick Corporation, Inc., Petitioner v. Drug Enforcement Administration, Respondent.chattem
Chemicals, Inc. and Mallinckrodt, Inc., Intervenors, 491 F.3d 483 (D.C. Cir. 2007);
HEALTH AND SAFETY CODE
47
TITLE 6. FOOD, DRUGS, ALCOHOL, AND HAZARDOUS SUBSTANCES
SUBTITLE C. SUBSTANCE ABUSE REGULATION AND CRIMES
CHAPTER 481. TEXAS CONTROLLED SUBSTANCES ACT
Sec. 481.002. DEFINITIONS.
Sec. 481.062. EXEMPTIONS.
Sec. 481.0621. EXCEPTIONS.
Sec. 481.065. AUTHORIZATION FOR CERTAIN ACTIVITIES.
Sec. 481.111. EXEMPTIONS.
Sec. 481.121. OFFENSE: POSSESSION OF MARIHUANA.
HEALTH AND SAFETY CODE

TITLE 6. FOOD, DRUGS, ALCOHOL, AND HAZARDOUS SUBSTANCES
SUBTITLE C. SUBSTANCE ABUSE REGULATION AND CRIMES
CHAPTER 487. TEXAS COMPASSIONATE-USE ACT
SUBCHAPTER A. GENERAL PROVISIONS
Sec. 487.053. LICENSING OF DISPENSING ORGANIZATIONS AND REGISTRATION OF

CERTAIN ASSOCIATED INDIVIDUALS.
SUBCHAPTER C. LICENSE TO OPERATE AS DISPENSING ORGANIZATION
Sec. 487.101. LICENSE REQUIRED.

Sec. 487.103. APPLICATION.
SUBCHAPTER E. DUTIES OF COUNTIES AND MUNICIPALITIES
Sec. 487.201. COUNTIES AND MUNICIPALITIES MAY NOT PROHIBIT LOW-THC

CANNABIS.
TITLE 5. GOVERNMENTAL LIABILITY

CHAPTER 110. RELIGIOUS FREEDOM
Sec. 110.001. DEFINITIONS.
48
Affidavit of Harm and Hardship
49
Correspondence from DPS regarding Compassionate Use Program
They say “High-THC Marijuana” though my request was for Strains with Lower amounts of THC and
Higher amounts of THCv but they were most likely spoken to by one of the people who obviously are
on a Crusade against my Religion.
50
Attainder and Exemption
"SECTION 2.
(a) It is the policy of this state that hemp is a
viable agricultural crop and an agricultural commodity in this state.
(b)It is the purpose of this Act to:
(1)promote cultivating and processing hemp and develop new commercial markets for farmers and
businesses through the sale of hemp products;
(2)promote the expansion of this state ’s hemp
industry to the maximum extent permitted by law allowing farmers and businesses to cultivate, handle,
and process hemp and sell hemp products for commercial purposes;
(3)encourage and empower research into hemp production and hemp products at institutions of higher
education and in the private sector; and
(4) move this state and its citizens to the forefront of the hemp industry" -TX House Bill 1325
Gonzales v. O Centro Espírita Beneficente União do Vegetal, 546 U.S. 418 (2006); Gonzales v.
Raich, 545 U.S. 1 (2005) (affirming that Congress may regulate personal Marijuana use as Interstate
Trade); Burwell v. Hobby Lobby, 573 US ___(2014) (ACA held to be in Violation of Religious Right
to believe Fetuses have Souls); Mellouli v. Lynch, 575 US ___(2015) (A case using the Cocaine Tax
Law/Harrison Tax Act where the CSA is not definitive, showing the CSA is a generational member of a
family of Laws, and not some alien lifeform immune to Fundamental Law); Linder v. United States,
268 US 5 (1925) (Harrison Narcotics case Stating "direct control of Medical practice in the States is
beyond the power of the Federal Government"); Dent v. West Virginia, 129 U.S. 114 (1889)
(Attainder case, and first case to mandate State Licensed Medical Doctors, and State Medical Boards).
See also, Cantwell v. Connecticut, 310 U.S. 296 (1940); Board of Medical Examiners v. Nzedu, 228
S.W.3d 264 (Tex. App. 2007); Untitled AG Opinion No. RQ-0367-JC (Tex. Att'y Gen. 2001);
Untitled Texas Attorney General Opinion, GA-0289 (Tex. Att'y Gen. 2005); Untitled Texas
Attorney General Opinion, GA-0384 (Tex. Att'y Gen. 2005); Earth Science Tech, Inc. v.Impact
UA, Inc., 19-10118 (11th Cir. 2020); Applications To Become Registered Under the Controlled
Substances Act To Manufacture Marijuana To Supply Researchers in the United States, 81 FR
53846, 21 CFR 1301; Hemp Industries Association v. DEA, Nos. 03-71366, 03-71693 (2004);
United States v. ARTICLE OR DEVICE, ETC., 333 F. Supp. 357 (D.D.C. 1971)
The American Declaration of the Rights and Duties of Man Article 13- Right to the
Benefits of Culture
Universal Declaration of Human Rights, G.A. res. 217A (III), U.N. Doc A/810 at 71 (1948).
Article 18
51
International Covenant on Civil and Political Rights, G.A. res. 2200A (XXI), 21 U.N.
GAOR Supp. (No. 16) at 52, U.N. Doc. A/6316 (1966), 999 U.N.T.S. 171, entered into force
Mar. 23, 1976.
Article 18
Declaration on the Elimination of All Forms of Intolerance and of Discrimination Based

on Religion or Belief, G.A. res. 36/55, 36 U.N. GAOR Supp. (No. 51) at 171, U.N. Doc.
A/36/684 (1981).
Article 1, Article 2, Article 4, Article 6, Article 7
Special Rapporteur on freedom of religion or belief (1986)

The Special Rapporteur has been mandated through Human Rights Council resolution
6/37
Human Rights Committee, General Comment 22, Article 18 (Forty-eighth session,

1993). Compilation of General Comments and General Recommendations Adopted by
Human Rights Treaty Bodies, U.N. Doc. HRI/GEN/1/Rev.1 at 35 (1994)
Request/Conclusion
I request declaratory relief as to Religious Issues and Criminal acts of the County and State, as well as a
lifting of the Vexatious litigant order intended to harm my Religious Exercise and ability to access the
Courts.
This is a Challenge under Texas Code Title 5 Chapter 110 (Texas RFRA), Texas Constitution Article 1,
Sec 6 (Right to Worship according to conscience), Sec 13 (Access), Sec 19 (Deprivation of Rights
under Color of Law), Sec 27 (Right to Petetion for Redress and Remonstrance), Sec 29 (Inviolate by
Written Law), and U.S. Constitution Article I, Sec 9, Clause 3 (No Laws of Attainder), 1st Amendment
(Religion, Speech, Redress of Grievances), 5th Amendment (Due Process), 14th Amendment (Due
Process, Equal Protection) to Texas Law Chapter 11 (Vexatious Litigant Law) and Texas Health and
Safety code Chapter 481 (TX CSA) as applied.
And Criminal Accusations against Bob Davis, Cynthia Wheless, Christine Nowak, Ken Paxton and
Greg Abott under Tex. Civ. Prac. Rem. Code Sec 41 (Negligence), 18 U.S. Code Sec 242 (Deprivation
52
of Rights Under Color of Law), RICO 18 U.S. Code Sec 1962 (Public Corruption), Tex. Pen. Code Sec
37.03 (Aggravated Perjury), 37.01 (Tampering with Governmental Documents), False/Ommitted
Statements on Public Financial forms Tex. Pen. Code Chapter 37 (Perjury and Other Falsification).
S/_Ryan_Gallagher___
Rev. Ryan “Sasha” Gallagher
[email protected]
8150 N Stemmons fwy
Dallas, TX 75247
53
State of Texas
County of ___________
Before me, ___________ (insert the name and character of the officer), on this day personally
appeared_________________________________, known to me (or proved to me through
_______________________ (description of identity card or other document) to be the person whose
name is subscribed to the foregoing instrument and acknowledged to me that he executed the same for
the purposes and consideration therein expressed. Given under my hand and seal of office this ______
day of ________, 20___.
(Seal)
____________________
Notary Public Signature
54

1960s Hanrahan Case Law in Texas T.R.A.P. Collin County Corruption Brief, Gallagher/Van-Kush v. Collin County, 05-20-00098-CV

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Table of Contents

Introduction: Commanding Precedent… 1

Statement of the Case … 4

Summary of the Argument… 36

In Re: Gallagher, ​WR-90,174-01

Allen Glenn Thomas v. Texas Department of Criminal Justice-Institutional Division,

Written Law & US Constitution

TX ARTICLE 1, BILL OF RIGHTS

Government Record and News

Applications To Become Registered Under the Controlled Substances Act To Manufacture

Police Report #20023116 ​24

Introduction: Commanding Precedent

Tilton v. Marshall, 925 S.W.2d 672 (Tex. 1996)

Sec. 402.010. LEGAL CHALLENGES TO CONSTITUTIONALITY OF STATE STATUTES

Freedom of Speech and Right to Criticize Public Officials

A. Rule 270 Reopening and Merging Cases & Statute of

1. Because he doesn't like my Religion

2. Because Statute of limitations is up in his mind

3. Because of Sovereign Immunity

(2) Motion to Merge

Tex. R. Civ. P. 270

(January 23, 2020; 9:23 a.m.)

(1) Texas Jurisdiction

City of Beaumont v. Bouillion, 896 S.W.2d 143 (Tex.1995)

(2) Federal Question Jurisdiction

28 U.S. Code§ 1337.Commerce and antitrust regulations; amount in controversy, costs

(3) Ultra Vires & Anti-Trust Law

C. Negligence/Noble Cause Corruption

F. Sovereign Immunity Waived and Destruction of

This is “Team Paxton”

G. Bob Davis: Aggravated Perjury & Fraud on the Court

(1) Fraud on the Court

(2)Texas Penal Code § 37.03. Aggravated Perjury

H. Judge Cynthia Wheless (Illegal Sanctions, Void Orders,

(2) Vexatious Litigant Designation

I. Greg Abbott and Ken Paxton: Conflict of Interest

Summary of the Argument

2. Because Statute of limitations is up in his mind

3. Because of Sovereign Immunity

I filed in response to the Defendants, and gave me Sanctions

Johnson, Dietrick Lewis Sr., WR-83,532-01 (Tex. App. 2015)

B. Constitutional Challenge to a Statute & Mandamus

The Volstead Act

TEXAS ALCOHOLIC BEVERAGE CODE

HEALTH AND SAFETY CODE

HEALTH AND SAFETY CODE

Sec. 487.053. LICENSING OF DISPENSING ORGANIZATIONS AND REGISTRATION OF

SUBCHAPTER C. LICENSE TO OPERATE AS DISPENSING ORGANIZATION

Sec. 487.101. LICENSE REQUIRED.

SUBCHAPTER E. DUTIES OF COUNTIES AND MUNICIPALITIES

Sec. 487.201. COUNTIES AND MUNICIPALITIES MAY NOT PROHIBIT LOW-THC

TITLE 5. GOVERNMENTAL LIABILITY

Declaration on the Elimination of All Forms of Intolerance and of Discrimination Based

Special Rapporteur on freedom of religion or belief (1986)

Human Rights Committee, General Comment 22, Article 18 (Forty-eighth session,

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In Re: Gallagher, WR-90,174-01

Police Report #20023116 24