Open Records Requests for City of Hun...

Since: Jul 12

Katy, TX

#192 Mar 21, 2013
11. The names of the attorneys who will appear on behalf of the parties at the
management conference (the appearing attorney must be an attorney of record and
have full authority to bind the client).

12. Any other matters counsel deem appropriate for inclusion in the joint conference
report.

CONTESTED MOTION PRACTICE

Counsel and parties shall comply with Local Rules CV-7, 10, 11, and 56, in addition to
the Federal Rules of Civil Procedure. Local Rule CV-7 requires you to attach affidavits and other
supporting documents to the motion or response. Labeled tabs on the attachments to the courtesy
copy will make it easier to find them.

If the motion with attachments exceeds 20 pages, the court requests that you bind (spiral
or otherwise) the courtesy copy at the left to make it easier to read.

Pursuant to Local Rule CV-7(b), highlight in the courtesy copy, the portions of the
affidavits or other supporting documents which are cited in your motion or response.

Since: Jul 12

Katy, TX

#193 Mar 21, 2013
Initial mandatory disclosure pursuant to Rule 26(a)(1) shall be completed not later than
28 days after the deadline for the Rule 26 attorney conference and shall include the following in
addition to information required by Rule 26(a)(1):

1. The correct names of the parties to the action.

2. The name and, if known, address and telephone number of any potential parties to
the action.

3. The name and, if known, the address and telephone number of persons having
knowledge of facts relevant to the claim or defense of any party, a brief
characterization of their connection to the case and a fair summary of the
substance of the information known by such person. This may be combined with
list of persons required under Rule 26(a)(1)(A)(i) so two lists are not needed.

4. The authorizations described in Local Rule CV-34.

5. A copy of all documents, electronically stored information, witness statements,
and tangible things in the possession, custody, or control of the disclosing party
that are relevant to the claim or defense of any party. This may be combined with
disclosures under Rule 26(a)(1)(A)(ii) so duplication is avoided. In cases
involving a disproportionate burden of disclosure of a large number of documents
on one party, the parties may agree on prior inspection to reduce the need for
copy. Parties are encouraged to agree upon provision of information by electronic
means.


See Local Rule CV-26(d) for meaning of “relevant to the claim or defense of any party.”
A party that fails to timely disclose such information will not, unless such failure is
harmless, be permitted to use such evidence at trial, hearing or in support of a motion. A
party is not excused from making its disclosures because it has not fully completed its
investigation of the case.

Discovery shall not commence until the deadline set for the attorneys to confer under
Rule 26(f). See Fed. R. Civ. P. 26(d). Depositions may be taken, and initial mandatory
-4-
Case 9:12-cv-00210-RC Document 4 Filed 02/14/13 Page 5 of 9 PageID #: 15
disclosure shall occur, before the Rule 16 management conference, so that counsel are in a
position to intelligently discuss additional required discovery, and scheduling of the case.
Following the management conference, the court will enter a scheduling order setting deadlines
controlling disposition of the case. If the court concludes that a management conference is not
necessary after receiving the parties’ 26(f) report, it may enter a scheduling order and cancel the
management conference.

The fact that the scheduling order will have a deadline for completion of discovery is
NOT an invitation, or authorization, to withhold documents or information required to be
disclosed as part of initial mandatory disclosure, under the guise of “supplementation.” Attorneys
are expected to review their client’s files and to conduct at least preliminary interviews of their
clients and potential witnesses under their control, so as to fully comply with the initial
mandatory disclosure requirements by the deadline set in this order. This will allow experts to be
timely identified and prepared to testify, witnesses to be efficiently deposed, and any follow-up
paper discovery to be completed by the deadline to be set for completion of discovery. The court
expects that, in most cases, after reading the pleadings and having a frank discussion of the
issues and discovery during the Rule 26 attorney conference, a review of the opposing party’s
initial disclosures should alert an attorney to any remaining information which should have been
disclosed, so that such information can be provided before the Rule 16 management conference.
A party asserting that any information is confidential should immediately apply to the court for
entry of a protective order. Unless a request is made for modification, the court will use the form
found on the Eastern District website

Since: Jul 12

Katy, TX

#195 Mar 21, 2013


COMPLIANCE

Attorneys and pro se litigants who appear in this court must comply with the deadlines
set forth in the Federal Rules of Civil Procedure, the Local Rules for the Eastern District of
Texas and this order. A party is not excused from the requirements of a Rule or scheduling
order by virtue of the fact that dispositive motions are pending, the party has not
completed its investigation, the party challenges the sufficiency of the opposing party’s
disclosure, or because another party has failed to comply with this order or the rules.

Failure to comply with relevant provisions of the Local Rules, the Federal Rules of Civil
Procedure, or this order may result in the exclusion of evidence at trial, the imposition of
sanctions by the court, or both. Counsel are reminded of Local Rule AT-3, particularly AT-3(I)
& (J).

  So ORDERED and SIGNED on February _____, 2013. 14




__________

Ron Clark
United States District Judge
What - Where

Katy, TX

#196 Mar 22, 2013
WTH ?

“Doing what's right....”

Since: Aug 12

Huntington, Texas

#197 Mar 22, 2013
Up Up & Away- with your name all over the newspaper, do you really think it is such a great idea to keep trying to pull these people down with you? All of these postings are ridiculous and you are really making your entire "group" look bad. You have so much time on your hands, and it looks like you need another hobby. Some of the people you are trying to 'lead' might actually have a personal interest in things (even if they are going about it wrong). If you want to help people learn how to carry out personal vendettas against someone, try starting a website? This way the 1 or 2 people who might care what you have to say can access that site. You are using this website to SPAM your ideas. I, for one, am a little tired of scrolling past all your nonsense to read what people are actually saying.
wanna know

Katy, TX

#198 Mar 23, 2013
The word "vendettas" is used somewhat frequently in these post so I looked up the definition and it means to 1. To inflict punishment in return for (injury or insult). My point being the language being used indicates these people were actually wronged initially and most likely did not receive justice because if they had received justice there would be no need for "vendetta". Right?? So instead of concentrating on their "vendetta" why not focus on eliminating the injustice because after all America is supposed to be a country with "Justice for All"

Since: Jul 12

Location hidden

#199 Mar 23, 2013
wanna know wrote:
The word "vendettas" is used somewhat frequently in these post so I looked up the definition and it means to 1. To inflict punishment in return for (injury or insult). My point being the language being used indicates these people were actually wronged initially and most likely did not receive justice because if they had received justice there would be no need for "vendetta". Right?? So instead of concentrating on their "vendetta" why not focus on eliminating the injustice because after all America is supposed to be a country with "Justice for All"
Thank you!
It does seem they want to group us all up into a neat little group, the "troublemakers" with all those nasty "vendettas" in the works. The wrongs done to some individuals are just the tip of the iceberg. And many of us have only what we have seen and heard that has made us ask questions to get us lumped into that same pile. This tactic has worked so well in the past for them that they figured it would work again.
This time things will be different, the Citizens have realized that everything does not have to stay the same in Huntington. There's a new wind blowing into town and it will clean out all those dirty little secrets. In the future when we play the game, we'll all play by the same rules.

“Doing what's right....”

Since: Aug 12

Huntington, Texas

#200 Mar 25, 2013
@wanna know- All of that, and you took away only one word? I am very happy that you are able to use a dictionary, but maybe you should put it to better use? Look up gossip. Or spam. You have no issues with the repeated posts over the exact same requests over & over?(Sometimes the posts are so long, they have to post 4 or 5 times to make it all fit) Did you read the news articles about someone in this "group" requesting over 200,000 records from many different cities? For what reasons? Yes, I still believe the word vendetta is accurate. If a member of someone's family feels they were "wronged" or if someone feels they were "mistreated", and now they use personal attacks & 200,000+ open records requests- I think I used the word as it was meant.

@inacar- You say you're playing games, I really don't agree with that either. Games are best left at the playground, not politics.(Even though I know that is difficult at times, whether it is local politics or not). As for lumping everyone together- you can't soar with the eagles when you squat with the buzzards. Association can be a hard thing to shake. If you associate yourself with someone who is dragging you & your "cause" through the mud, expect to be looked at as muddy.

Since: Jul 12

Montgomery, TX

#201 Mar 26, 2013
"As for lumping everyone together- you can't soar with the eagles when you squat with the buzzards. Association can be a hard thing to shake. If you associate yourself with someone who is dragging you & your "cause" through the mud, expect to be looked at as muddy."

ActuallyInHungintgon: You said it very well, however you should remember, you are grouping people that may or may not know each other well, if even at all. As for the 'reason' requests are being made, I will say it again, it is NO ONE'S business.... even the entity to whom the request was made cannot ask. I see record requests as the people wanting to know what is going on. Every government entity has an open records policy - check into it... want more information, request it. If it were easy enough to gain an answer from one single request that would be nice, however, some entities are 'covering' or 'hiding' things and hence more requests are needed to dig through to find the answers. Apparently you haven't looked for something specific from an entity that required a lot of digging. Maybe you are like the majority and just 'believe' what you are being told without asking questions. That is why our government - all the way to the White House - is in the sad shape it is in.

“Doing what's right....”

Since: Aug 12

Huntington, Texas

#202 Mar 26, 2013
Manuela wrote:
"As for lumping everyone together- you can't soar with the eagles when you squat with the buzzards. Association can be a hard thing to shake. If you associate yourself with someone who is dragging you & your "cause" through the mud, expect to be looked at as muddy."
ActuallyInHungintgon: You said it very well, however you should remember, you are grouping people that may or may not know each other well, if even at all. As for the 'reason' requests are being made, I will say it again, it is NO ONE'S business.... even the entity to whom the request was made cannot ask. I see record requests as the people wanting to know what is going on. Every government entity has an open records policy - check into it... want more information, request it. If it were easy enough to gain an answer from one single request that would be nice, however, some entities are 'covering' or 'hiding' things and hence more requests are needed to dig through to find the answers. Apparently you haven't looked for something specific from an entity that required a lot of digging. Maybe you are like the majority and just 'believe' what you are being told without asking questions. That is why our government - all the way to the White House - is in the sad shape it is in.
I don't even know why you wasted time with that post? Asking for records isn't the problem- it is the over abundance of the requests that I see as unnecessary. I have always said that I had no problem with people (that have SO MUCH time on their hands by the way) asking for records. If you all have nothing else better to do- go for it. But asking for hundreds of thousands? And yes, it is apparent that all the buzzards are in the mud together. That is by no fault of mine. They really should have been more careful of who they associate with, especially when said buzzards wind up in the paper.
You say this all is no one's business? So you are telling us to sit down & shut up & not ask questions when it is about what you are doing? That makes no sense. If you can ask- so can everyone else. You might get answers faster than we will though. You then finish your comment by saying that the majority doesn't ask questions- make up your mind. Again I say it- if you can ask- so can we.

Since: Jul 12

Location hidden

#203 Mar 26, 2013
"Thumbs up!" Manuela, if my "judge it" worked, that's what it would be.
Diddly Squat

Katy, TX

#205 Apr 1, 2013
Manuela wrote:
"As for lumping everyone together- you can't soar with the eagles when you squat with the buzzards. Association can be a hard thing to shake. If you associate yourself with someone who is dragging you & your "cause" through the mud, expect to be looked at as muddy."
ActuallyInHungintgon: You said it very well, however you should remember, you are grouping people that may or may not know each other well, if even at all. As for the 'reason' requests are being made, I will say it again, it is NO ONE'S business.... even the entity to whom the request was made cannot ask. I see record requests as the people wanting to know what is going on. Every government entity has an open records policy - check into it... want more information, request it. If it were easy enough to gain an answer from one single request that would be nice, however, some entities are 'covering' or 'hiding' things and hence more requests are needed to dig through to find the answers. Apparently you haven't looked for something specific from an entity that required a lot of digging. Maybe you are like the majority and just 'believe' what you are being told without asking questions. That is why our government - all the way to the White House - is in the sad shape it is in.
I had a top secret clearance in the military, but that didn't entitle me to go around looking at anything.
There had to be a "Need To Know."

This ABUSE is exactly what will bring about changes in what some of you claim is your "unfettered" right to get any record you want.

Since: Jul 12

Location hidden

#206 Apr 7, 2013
Diddly, I would welcome you to call me, so you can see what I have requested and see if you still feel people should not be allowed to ask for open records? See if you are satisfied with the "answers" I have received. You say open records requests waste taxpayers money? Just how do we know where taxpayer's money is wasted if we don't ask for the records? If we only go by what we are told, that is when taxpayer's money becomes wasted. It takes people paying attention and getting involved. I also can say asking for records is opening a can of worms, one request does not give the final answer unless you really don't want the answer. Or at least that is my experience with Huntington open records requests.

Since: Jul 12

Location hidden

#207 Apr 7, 2013
TEXAS GOVERNMENT CODE 552.002. DEFINITION OF PUBLIC
INFORMATION; MEDIA CONTAINING PUBLIC INFORMATION.
(a) In this chapter, "public information" means information that is collected, assembled, or
maintained under a law or ordinance or in connection with the transaction of official business:
(1) by a governmental body; or
(2) for a governmental body and the governmental body owns the information or has a right
of access to it.
(b) The media on which public information is recorded include:
(1) paper;
(2) film;
(3) a magnetic, optical, or solid state device that can store an electronic signal;
(4) tape;
(5) Mylar;
(6) linen;
(7) silk; and
(8) vellum.
(c) The general forms in which the media containing public information exist include a book,
paper, letter, document, printout, photograph, film, tape, microfiche, microfilm, photostat,
sound recording, map, and drawing and a voice, data, or video representation held in
computer memory.
Added by Acts 1993, 73rd Leg., ch. 268, Sec. 1, eff. Sept. 1, 1993. Amended by Acts 1995,
74th Leg., ch. 1035, Sec. 2, eff. Sept. 1, 1995.
ADKISSON

Since: Jul 12

Montgomery, TX

#208 Apr 7, 2013
Diddly Squat wrote:
<quoted text>
I had a top secret clearance in the military, but that didn't entitle me to go around looking at anything.
There had to be a "Need To Know."
This ABUSE is exactly what will bring about changes in what some of you claim is your "unfettered" right to get any record you want.
You keep throwing your "top secret clearance in the military" out there. I do respect those who have been in the military and served our country. I myself am a product of the military, I have family members who were in the military. BUT the military and it's 'clearance' is a tad bit different than the City of Huntington. You see, they are run by the government - the same government that has the rules that you are so offended by when it comes to open records. Let me put this in a bit of a different perspective for you: What if, you put me in charge of all your finances... Gave me total control of how the money was spent and where I spent it. And then I in turn NEVER allowed you to see what I was doing with YOUR money. If I told you it was none of your business what I did with YOUR money you would not take to kindly to that. Even more, if I lied to you about EXACTLY how I used your money 'to your benefit I would say','to make things nicer and easier for you' I would say, when in actuality it was being used for my personal gain, you would not take kindly to that either. You would want, no, demand to know what your money was being used for. You would want to know that it was being handled appropriately. I know that sounds way off base, but basically, that is one of the things that the open records requests are for, to assure the citizens of ANYTOWN, USA to understand how their tax dollars are being used. This applies not just to local levels, but national levels as well. When an entity places a proposition to the voters regarding a tax hike, they 'explain' what the extra generation of money is to be used for. When it is your money that is being 'taken' from you for increased taxes, don't you want to know why? I don't know about you, but I do know there are a lot of people who have to watch their pennies to make ends meat, and when you start taking those pennies, one at a time, they want to know why. Just a little something for you to ponder. Have a nice day.
Diddly Squat

Katy, TX

#209 Apr 7, 2013
EXCESS !!!! REVENGE !!!! MAKE ONE FEEL IMPORTANT !!!!

I remember the saying, "Your rights end where my rights begin."

I have no problem with someone requesting government records to 'accomplish' something. They are planning to do something with them, like run for office, inform the people of wrongdoing with tax money etc is acceptable.

Doing it for no legitimate reason, or just because you can, is NOT acceptable.
Diddly Squat

Katy, TX

#212 Apr 8, 2013
David Stua wrote:
I accidentally hit the post button before I had completed my editing of the above post.
And you Sire, omniscience one, know that my requests are for "no legitimate reason?"
How would you know if you have not seen my requests and have not talked to my personally?
Again, you model your omniscience.
You have berated posters to topix about not being a citizen of Huntington. Niether are you according to your statements. You have asked people who they are and what their name is, Yet, you do not do the same.
I use my real name and location. Why don't you?
I have on multiple posts presented my 70 plus year connection to Huntington from being born in a share cropper house behind (what is now) Little Flock church delivered by Dr Stewart.
I also attended Huntington Schools with many of the movers and shakers of Huntington in the 40's and 50's.

Other than my time in the military and a few limited time jobs elsewhere, I have owned property, lived in or very near the Huntington city limits, sent my children and grandchildren to Huntington schools, paid taxes, and shopped in Huntington. I have usually shown and stated my residence as Lufkin since it is the county seat and my telephone number is with the Lufkin Tele Company and I had a PO Box there when I owned a business, but my home address is Huntington.

During my time in the military and away from Angelina County and still today, I subscribed to The Lufkin News and the Diboll Free Press. I also listed my "Home of Record", obtained an absentee ballot and voted here.

So I am completely justified in my claim of residency.

Now lets see YOUR history and justification.
Diddly Squat

Katy, TX

#215 Apr 9, 2013
RE David Stua's "Perhaps you would share your real name. Many don't because they are afraid of retaliation from the City of Huntington and other cities. If you want to make the government mad, just send them an open records request. They don't look at it the way they should, they don't like you inquiring into their affairs."

1. Let me think about this a bit.
2. How will me providing my 'real' name help?
3. I have no fear of anything the City of Huntington could do to "me", but I have to think of 'others' who may have a connection to me.
4. Do you want to explain/elaborate on "Up Up and Away" ?

Since: Jul 12

Location hidden

#216 Apr 12, 2013
David Stua is your ears burning? Seems you now have credit for BG having 6 hours of work a day to do just for you.

Since: Jul 12

Location hidden

#218 Apr 13, 2013
Oh just comments from the EDC meeting, I guess you also must take credit for the Trail's grant now having to be done by Grant Works. Another $2,000 you have cost the EDC due to the work load BG now has due to open records requests.

Tell me when this thread is updated:

Subscribe Now Add to my Tracker

Add your comments below

Characters left: 4000

Please note by submitting this form you acknowledge that you have read the Terms of Service and the comment you are posting is in compliance with such terms. Be polite. Inappropriate posts may be removed by the moderator. Send us your feedback.

Lufkin Discussions

Title Updated Last By Comments
Election Who do you support for State Board of Education... (Oct '10) Jun 13 robert 994
Mc gangs in Nac May 27 FW Daughter 2
reagan mcclain May '16 what 2
Lufkin industries (Sep '15) May '16 Mikey 4
Ben Curtis Affair (Mar '15) May '16 Huckleberry 13
Rodney wells May '16 Chris 1
Looking to move to Nacogdoches (Dec '09) May '16 Live_between_lufk... 87
More from around the web

Personal Finance

Lufkin Mortgages