Strangmeier v. The City of Houston Texas et al

Filing 31

RESPONSE in Opposition to 30 MOTION for Sanctions, filed by John Strangmeier. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Proposed Order)(Kallinen, Randall)

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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS, HOUSTON DIVISION JOHN STRANGMEIER, INDIVIDUALLY, and on behalf of a Class of All Similarly Situated Persons, Plaintiff, )( )( )( V. )( THE CITY OF HOUSTON, TEXAS, and MAYOR ANNISE PARKER, INDIVIDUALLY; )( )( Defendants. CIVIL ACTION NO.: 4:11-cv-3463 )( JURY TRIAL Declaration of John Strangmeier’s Counsel Randall Kallinen Pursuant to 28 U.S.C. § 1746, I, Randall L. Kallinen, Esq., swear to the truth of the following statements, based on my personal knowledge thereof: 1. Identity and qualifications. My name is Randall L. Kallinen. I am qualified to offer this sworn declaration regarding the null and void sanctions motions filed by the City of Houston (the “City”) and Mayor Parker which was filed days after this case was dismissed by notice of dismissal. I am an attorney admitted to practice in the State of Texas for over seventeen years. I am over the age of 18 years, and of sound mind. I have never been convicted of a felony or crime of moral turpitude. Everything I say in this sworn declaration is true, and subject to the penalties for perjury. 2. I am familiar with my client John Strangmeier. He is not an attorney. He is a represented client. To confirm that he is not a lawyer, I also checked the State Bar of Texas’ website to see if the name John Strangmeier appears in the State Bar’s list of Texas attorneys. It 1 does not. Nothing that John Strangmeier or I did in the now dismissed case-CIVIL ACTION NO.: 4:11-cv-3463-was vexatious, frivolous, harassing, meant to delay or increase the cost of litigation nor done for any other improper purpose. Neither did I have bad faith, reckless disregard for duty owed to the court or improper motive. Because this case is dismissed under FRCP 41(a)(1) the sanctions motion filed by the City and Mayor Parker is null and void. 3. I never filed anything in this Court to vex this Court, the City or Mayor Parker. I never filed anything in this Court to harass any party or its counsel. Everything I filed in this Court reflects my legitimate efforts to help my client John Strangmeier with his legitimate claims. 4. On May 24, 2012 I on behalf of John Strangmeier filed a Notice of Dismissal in the above entitled and numbered cause which immediately ended the case upon filing. I have never filed anything nor indicated in any way that any motion to dismiss was filed. 4. I declare under penalty of perjury that the foregoing is true and correct. Dated: June 28, 2012. By: 2 /s/ Randall L. Kallinen Randall L. Kallinen

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