Federal Civil Rights Action
United States District Court | Northern District of Texas – Lubbock Division
Civil Action No. — Pending Assignment
Civil Action Filed Under: 42 U.S.C. Sec. 1983 – Civil Rights Violations
Chronological Record of Events:
ResJudicataClaim.com
Chronological Record of Events
The following timeline summarizes the documented sequence of events forming the evidentiary record supporting the federal civil rights claim presented on this website. Each entry corresponds to documentation contained within the exhibits filed in the federal action.
September 11, 2024
Actors: Officers Zachory Tyler
Carter, Shane Allen Rackley, Vance Wright Listwan, Ryan Clay Reeves,
and John Doe–1 (“Aaron”).
Agency: CITY OF SNYDER,
Inc. Police Department
Plaintiff’s privately owned vehicle
was seized following issuance of Citation No. E020937.
Plaintiff’s First "verbal" request for business cards and bond information from officers was denied.
Constitutional Issues:
Fourteenth Amendment – Due Process
Evidence
Reference:
1 Page | CERTIFIED
Copy of Original September 11, 2024 Citation E020937
September 27, 2024
1 | Plaintiff dispatched NOTICE of COUNTERCLAIM concerning Citation No. E020937 via USPS Registered Mail to nine (9) named parties. The COUNTERCLAIM itself had the Second request for bond information at Page 16 of EXHIBIT A
Zachory Tyler Carter, Shane Allen Rackley,
Vance Wright Listwan, Ryan Clay Reeves, Mike Adam Counts, Elias Vasques
Torres, Stephanie Ducheneaux, David Scott Brown, CITY OF SNYDER, Inc.
2 | An Olive Branch offer was delivered to David Scott Brown offering removal from the COUNTERCLAIM if the vehicle was returned.
3
| Texas Public
Information Act (TPIA) Third
request for bond information was issued to the CITY
OF SNYDER,
Inc. Secretary’s Office.
Evidence Reference:
1 | Pages 2 – 46 | EXHIBIT
A
2 | Page 39 | EXHIBIT A
3 |
Pages
3
– 5 | EXHIBIT
C
USPS Certified
Mail Proof of Service
PS-3811 Receipts:
1 | Pages 47 – 60 | EXHIBIT
A
2 | Page 57 | EXHIBIT A
3 |
Pages
6
| EXHIBIT
C
September 30, 2024
CITY OF SNYDER,
Inc., Deputy Secretary,
responded to Plaintiff’s TPIA request but did not provide bond
information.
Constitutional
Issues:
Fourteenth Amendment — Procedural Due Process
Evidence
Reference:
Pages
5
– 6 | EXHIBIT
C
October 1, 2024
CITY OF SNYDER,
Inc., MUNICIPAL COURT – October 3, 2024, Posted via USPS –
NOTICE – INITIAL COURT
SETTING (ART.
45.014 C.CP.) for two charges under CAUSE NUMBERS E020937-1
and E020937-2 with a court date of October 29, 2024.
NOTICES
were received on October 5, 2024, despite being a named party
to the
pending COUNTERCLAIM.
Constitutional Issues:
First Amendment — Right to Petition for Redress
Evidence
Reference:
Pages 5 — 6 | EXHIBIT
D
October 10, 2024
Plaintiff
tendered written response to
the announcement of October 29, 2024, CITY OF SNYDER, Inc.,
MUNICIPAL
COURT date.
Evidence Reference:
Pages 7 — 17 | EXHIBIT
D
October 10, 2024
Plaintiff tendered a response to the CITY OF SNYDER, Inc., Deputy Secretary with an additional Texas Public Information Act request seeking bond information.
Evidence
Reference:
Pages
7
– 12 | EXHIBIT
C
USPS Certified
Mail Proof of Service
PS-3811 Receipts:
Pages
14
– 15 | PS Form 3811’s – Proof of Service of response
October 11, 2024
CITY OF SNYDER,
Inc., Deputy Secretary,
responded to Plaintiff’s 2nd written TPIA request but did
not
provide bond information. Plaintiff realized from this 2nd response that the
Secretary's Office was only going to refer the matter to the Office of
the Texas Attorney General, and that it was pointless in further
requests to a non-responsive
party.
Constitutional
Issues:
Fourteenth Amendment — Procedural Due Process
Evidence
Reference:
Pg. 13 | EXHIBIT
C
October 21, 2024
1 | Plaintiff dispatched NOTICE of Dishonor & Opportunity to Cure to fourteen named parties (14) regarding the pending COUNTERCLAIM.
Zachory
Tyler Carter, Shane Allen Rackley, Vance Wright Listwan, Ryan Clay
Reeves, Mike Adam Counts, Elias Vasques Torres, Stephanie Ducheneaux,
David Scott Brown, CITY OF SNYDER, Inc.,
Additional Respondents: Jeffery John Caswell, Angela Rene Blair, Becki Lashai Green, Brad Scott Overcash, CITY OF SNYDER, Inc. MUNICIPAL COURT
2
| Stand-alone
TPIA bond-information demand was delivered in the same envelope as the NOTICE of
Dishonor & Opportunity to Cure.
Evidence Reference:
1
| Pages 61
- 68 | EXHIBIT A
2 | Pages 69 - 72 | EXHIBIT A
USPS Certified
Mail Proof of Service
PS-3811 Receipts:
1
& 2 | Pages 73
- 80 | EXHIBIT A
November 13, 2024
Administrative Default Judgment issued against fourteen parties following non-response to the perfected administrative process which began with the delivery of the September 27, 2024, COUNTERCLAIM.
Zachory Tyler Carter, Shane Allen Rackley, Vance Wright Listwan, Ryan Clay Reeves, Mike Adam Counts, Elias Vasques Torres, Stephanie Ducheneaux, David Scott Brown, CITY OF SNYDER, Inc., Jeffery John Caswell, Angela Rene Blair, Becki Lashai Green, Brad Scott Overcash, CITY OF SNYDER, Inc. MUNICIPAL COURT
Evidence Reference:
Pages
81
- 89 | EXHIBIT A
USPS Certified
Mail Proof of Service
PS-3811 Receipts:
Pages
90
- 99 | EXHIBIT A
November 14, 2024
CITY OF SNYDER, Inc., Police Sergeant Rustin David Webb executed two sworn complaints relating to the events of September 11, 2024, despite not being a present and firsthand witness the events of that day.
The
complaints
were received by Angela
Rene Blair, CITY OF SNYDER,
Inc., MUNICIPAL COURT Administrator and notarized Brad Scott
Overcash, both of whom were already parties to the active COUNTERCLAIM
at the time the documents were processed.
Evidence Reference:
Pages 20 — 21 | EXHIBIT
D
November 18, 2024
Bond DEMAND NOTICE issued to the Texas Municipal League Intergovernmental Risk Pool and associated executives, representing the Seventh request for bond information.
This record shows that not only have TMLIRP and executives been given NOTICE but also the Texas Insurance Commissioner, Cassie Brown.
Evidence
Reference:
Pages
25
— 36 | EXHIBIT
C
USPS Certified
Mail Proof of Service
PS-3811 Receipts:
Pages
25,
28, 37, 38 | EXHIBIT
C
November 14, 2024
CITY OF SNYDER,
Inc., MUNICIPAL COURT
issued a second set of summons and pre-trial notice relying upon two (2) sworn, yet deficient complaints.
Constitutional Issues:
First Amendment — Right to Petition for Redress
Evidence
Reference:
Pages
20
— 23 | EXHIBIT
D
November 21, 2024 – January 7, 2025
Public Notice
published in the Sweetwater
Reporter newspaper.
Evidence Reference:
Pages 1 | EXHIBIT
L
November 25, 2024
Plaintiff
tendered notarized response
to the CITY OF SNYDER, Inc., MUNICIPAL COURT pre-trial summons.
Evidence Reference:
Pages
24
— 28 | EXHIBIT
D
USPS Certified
Mail Proof of Service
PS-3811 Receipts:
Pages
29
– 30 | EXHIBIT
D
December 6, 2024
Preemptive notice
issued to the Scurry
County Clerk concerning recording of perfected administrative
documents. The notice
was also delivered to Secretary of State, Jane Nelson as a witness to
the facts.
Evidence Reference:
Pages
1
- 9 | EXHIBIT
E
USPS Certified
Mail Proof of Service
PS-3811 Receipts:
Pages
1
and 8 | EXHIBIT
E
December 16, 2024
Olive Branch NOTICE delivered via USPS Certificate of Mailing to fifteen named parties.
Zachory Tyler Carter, Shane Allen Rackley, Vance Wright Listwan, Ryan Clay Reeves, Mike Adam Counts, Elias Vasques Torres, Stephanie Ducheneaux, David Scott Brown, CITY OF SNYDER, Inc., Jeffery John Caswell, Angela Rene Blair, Becki Lashai Green, Brad Scott Overcash, Rustin David Webb, CITY OF SNYDER, Inc. MUNICIPAL COURT.
Evidence Reference:
Pages 5
– 16 | EXHIBIT
B
USPS Certified
Mail Proof of Service
PS-3811 Receipts:
Pages
2
– 3 | EXHIBIT
B
January 10, 2025
Additional Olive Branch NOTICE delivered to City Council members expanding the COUNTERCLAIM list to twenty-one individuals.
Zachory
Tyler Carter, Shane Allen Rackley, Vance Wright Listwan, Ryan Clay
Reeves, Mike Adam Counts, Elias Vasques Torres, Stephanie Ducheneaux,
David Scott Brown, CITY OF SNYDER, Inc., Jeffery John Caswell, Angela
Rene Blair, Becki Lashai Green, Brad Scott Overcash, CITY OF SNYDER,
Inc. MUNICIPAL COURT,
Also NOTICED: Sarah Ann Jamison, Timothy Carson Matthies, William 'Bill' Badger Robertson, Julian Roman Dominguez, Jerry Lee Webb, Ralph L Hernandez.
Evidence Reference:
Pages
17
– 41 | EXHIBIT
B
USPS Certified
Mail Proof of Service
PS-3811 Receipts:
Pages
3
– 4 | EXHIBIT
B
January 31, 2025
Olive Branch deadline expired with no performance by any named party and is when the following parties were added to the claim.
Added Respondents:
Sarah Ann Jamison, Timothy Carson Matthies, William 'Bill' Badger
Robertson, Julian Roman Dominguez, Jerry Lee Webb, Ralph L Hernandez.
February 14, 2025
Scurry County
Clerk issued the first refusal to record Plaintiff’s perfected Claim of Lien / Affidavit of Obligation,
which had been hand delivered for filing in the county records.
Constitutional Issues:
Fourteenth Amendment — Access to Courts
Evidence
Reference:
Page 9 - 10 | EXHIBIT-E
March 7, 2025
Plaintiff
received notice from the
Scurry County Clerk, Melody Ann Appleton on February 20,
2025,
and mailed rebuttal to county officials concerning the allegation that
the
documents tendered were fraudulent.
Evidence Reference:
Pages
10
– 28 | EXHIBIT-E
USPS Certified
Mail Proof of Service
PS-3811 Receipts:
3 Pages | NOTICE
to Appleton and Secretary of State, Jane Nelson
May 5, 2025
Second and Final
Bond DEMAND NOTICE
dispatched to TMLIRP executives, along with a NOTICE delivered to
Cassie Brown,
Texas Insurance Commissioner.
Evidence Reference:
Pages
28
– 36 | EXHIBIT
C
USPS Certified
Mail Proof of Service
PS-3811 Receipts:
Pages 37
– 38 | EXHIBIT
C
Stand-Alone
Mailed Presentment with USPS
Certified Mail Proof of Service:
12 Pages | TMLIRP
– NOTICE of Dishonor and Opportunity to Cure
May 16, 2025
Petition for
Enforcement of Perfected
Private Remedy filed in the 132nd District Court.
Scurry County Records Clerk issued second refusal to record Plaintiff's Claim of Lien / Affidavit of Obligation.
Added Respondents: Texas
MUNICIPAL League Intergovernmental Risk Pool, Humberto Gil Lumbreras,
Austin A Bleess, Charles 'Bo' Riley Joseph, Atul Laxmichand Poladia.
Evidence Reference:
120
Pages
| Petition
for Enforcement of Perfected Private Remedy
In Person Filing
– Proof of Service:
File time-stamped by 132nd
District Court Clerk, Cause #
25-208-DCCV-27862,
3:58 pm.
May 30, 2025
First Supplement
filed in the 132nd
District Court.
Evidence Reference:
5
Pages
| First
Supplement to Cause # 25-208-DCCV-27862
In Person Filing
– Proof of Service:
File time-stamped by 132nd
District Court Clerk, Cause #
25-208-DCCV-27862,
9:35 am.
June 24, 2025
Second Supplement
filed in the 132nd
District Court.
Evidence Reference:
29
Pages
| Second
Supplement to Cause # 25-208-DCCV-27862
In Person Filing
– Proof of Service:
File time-stamped by 132nd
District Court Clerk, Cause #
25-208-DCCV-27862,
10:55 am.
June 25, 2025
FINAL Opportunity
to Cure delivered to
Scurry County officials regarding refusal to record documents.
Evidence Reference:
27 Pages | FINAL
Opportunity to Cure Scurry County Records June 25, 2025
USPS Certified
Mail Proof of Service
PS-3811 Receipts:
Pages 26 – 27 | FINAL
Opportunity to Cure Scurry County Records June 25, 2025
June 30, 2025
Actors: Scurry County Judge Daniel Raymond Hicks Jr.
Scurry County District Attorney Michael
W. Hartman
Federal Question NOTICE delivered
via USPS Certified Mail presenting a federal constitutional question
concerning the duties of public officials under the Constitution and
laws of the United States.
Proof of service documents accepted
by the District Attorney’s
office and refusal by the County Judge.
Constitutional Issues:
First Amendment – Right of Petition
Fourteenth Amendment – Due Process
Evidence
Reference:
13 Pages | Federal Question Notice to Scurry County Officials
July 4, 2025
Plaintiff received Scurry County
Clerk's refusal to accept the FINAL NOTICE and Opportunity to Cure of June 25, 2025, which was accompanied by District Attorney letter alleging fraud for a second time.
Evidence Reference:
4 Pages | Scurry
County Clerks Response to Opportunity to Cure
September 10, 2025
RESOLUTION
RESCISSION AND REMOVAL OF ERRONEOUS RECORDS CONCERNING Copyright Claim
Invoice to CITY OF SNYDER, Inc. MUNICIPAL COURT.
Evidence Reference:
3 Pages | RESCISSION AND REMOVAL NOTICE
September 16, 2025
Plaintiff
notarized five chronological
records forming the evidentiary integrity of the perfected
administrative claim
filed.
Evidence Reference:
98
Pages | EXHIBIT A
— Chronology
Part 1 – Administrative Procedure
43 Pages | EXHIBIT B — Chronology Part 2 - Olive Branch
41 Pages | EXHIBIT C — Chronology Part 3 - TPIA Violations
35 Pages | EXHIBIT D — Chronology Part 4 - Municipal Court Malicious Prosecution
68 Pages | EXHIBIT E — Chronology Part 5 - Scurry County Clerk - Recording Denial
October 21, 2025
Plaintiff
delivered Notice of Intent
to Enforce
Cause No. 25-208-DCCV-27862.
Evidence Reference:
37 Pages | Notice
of Intent to Enforce Cause No. 25-208-DCCV-27862 and
Proof of Service.
December 3, 2025
Plaintiff
received NOTICE via USPS of Rule
91a Motion to Dismiss filed by attorney Aaron Matthew Wilkerson
in
Cause No. 25-208-DCCV-27862.
Evidence Reference:
2
Pages
| Rule
91a Motion to Dismiss
December 16, 2025
Plaintiff hand
delivered to the 132nd
District Court
Opposition to Rule 91a Motion to Dismiss Cause No.
25-208-DCCV-27862.
Evidence Reference:
50
Pages
| December
16, 2025, Opposition to Rule 91a Motion to Dismiss
December 23, 2025
132nd District
Court issued partial
dismissal order despite the cause being filed solely for public notice.
Evidence Reference:
3
Pages
| Partial
Dismissal Order by
the 132nd District Court
March ~ 2026
Documents Notarized for this Federal Civil Rights Suit:
The documents will appear here when they have been Notarized
Federal Civil Rights Suit Filed
Following the completion of the evidentiary record and administrative process, Plaintiff filed a federal civil rights action under 42 U.S.C. Sec. 1983 in the United States District Court for the Northern District of Texas – Lubbock Division.
Filed documents will appear here when they have been Notarized
Last
Updated: March 14, 2026
