DEFENDANT S COUNTERCLAIM. Cause No COUNTY OF BASTROP ET AL IN THE 21 ST Plaintiff and counter-defendant,

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1 DEFENDANT S COUNTERCLAIM COUNTY OF BASTROP ET AL IN THE 21 ST Plaintiff and counter-defendant, V. JUDICIAL William Michael Johnson Defendant and counter-plaintiff, DISTRICT COURT V. Lee Gordon, alleged State Bar # , and MCCREARY, VESELKA, BRAGG & ALLEN, P.C. each third-party Defendants. BASTROP COUNTY TEXAS DEFENDANT S COUNTERCLAIM 1. Discovery pursuant to T.R.C.P Discovery Control Plan By Rule (Level 2); and 2. This lawful counterclaim arises directly out of the misrepresentations of the so-called COUNTY OF BASTROP plaintiff and now counter-defendant, as well as [its] alleged attorney(s) Lee Gordon, alleged State Bar # ; and [the] MCCREARY, VESELKA, BRAGG & ALLEN, P.C. now each third party defendants in this cause Number: 9842; and 3. On the merit that the man, one, William Michael Johnson is now, by the initializing complaint as filed in the Cause Number 9842 matter, the harmed and damaged party, an aggrieved party; and by common law he is entitled to and does demand relief and the relief sought is stated to in this counterclaim and the initializing complaint s answer and 4. On the merit that the free man on the land William Michael Johnson, now the aggrieved party, who possesses all civil and social rights and clear title, authorized representative for WILLIAM MICHAEL JOHNSON, does reserve all rights including, and not limited to, the right at any time to modify or alter original answer and this counterclaim after discovery is commenced; and 5. Trial by fully informed Jury of peers is demanded on all causes raised herein; and here now is stated lawful DEFENDANT'S COUNTERCLAIM 1

2 COUNTERCLAIM FACTS AND TRUTH 6. It is a fact that the [free] man on the [Texas] land William Michael Johnson is being harmed and damaged by this the Cause Number: 9842 action before this court; and 7. It is an fact that, William Michael Johnson, as relating to this 9842 matter, through (attorney s) abuse of process, conspiracy, malicious prosecution, wrongful attachment, conversion, commonlaw fraud, intentional infliction of emotional distress, invasion of privacy, nuisance, trespass and conversion, is an [the] aggrieved party; and 8. It is an fact that, William Michael Johnson, as relating to this instant matter, now suffering from trespass and unlawful conversion, is an [the] aggrieved party; and 9. It is a fact that, COUNTY OF BASTROP does not exist; and the alleged 10. COUNTY OF BASTROP does not appear registered with the Secretary of State of Texas; and 11. It is a fact that, alleged Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, BRAGG & ALLEN, P.C. abused the discretion, public trust, social standing, financial standing, and influential position, which they may possess, in a manner adverse and detrimental to the man William Michael Johnson, in violation of solemn oath as a Public Officer, an Officer of the Court, The Rules of Court, and the Organic and Statute Laws of Texas; and further 12. It is a fact that, Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, BRAGG & ALLEN, P.C. refuses to accept any responsibility for the damage their unsubstantiated sham conduct has inflicted upon William Michael Johnson; Lee Gordon, alleged State Bar # ; and the MCCREARY, VESELKA, BRAGG & ALLEN, P.C. have attempted to execute a modern day trespass, seizure and destruction of William Michael Johnson s recorded and posted private property; and further 13. It is a fact that, Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, BRAGG & ALLEN, P.C. refuses to fully identify the real party of interest; and further 14. It is a fact that, William Michael Johnson, in good faith files this lawful counterclaim knowing that the losses incurred, as caused by Lee Gordon, alleged State Bar # ; and the MCCREARY, VESELKA, BRAGG & ALLEN, P.C. s reckless and notorious conduct, can never be recovered in full, however, he does seek to recover for damages to the fullest extent possible through this court and through the remedies provided by law and Jury; and further DEFENDANT'S COUNTERCLAIM 2

3 15. these calculated, deliberate and conspiratorial actions to, unlawfully trespass, and of conversion, and attempted TAKE of the private property of William Michael Johnson constitutes criminal conduct by Lee Gordon, alleged State Bar # ; and the MCCREARY, VESELKA, BRAGG & ALLEN, P.C. and violate the laws of Texas as well as the very peace and tranquility of the state; and further 16. the alleged COUNTY OF BASTROP ET AL and Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, BRAGG & ALLEN, P.C. fraudulently trespass and claim absent any valid proof of claim that they are entitled to William Michael Johnson s private property; and further 17. It is a fact that, Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, fact that alleged COUNTY OF BASTROP does not exist; and further 18. It is a fact that, Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, fact that alleged COUNTY OF BASTROP does not exist in the State of Texas; and further 19. It is a fact that, Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, BRAGG & ALLEN, P.C. have continued to perpetrate this fraud by concealing from the court the fact that alleged COUNTY OF BASTROP has no original note or other valid contract or agreement to trespass or to TAKE William Michael Johnson s private property; and further 20. It is a fact that, Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, fact that alleged COUNTY OF BASTROP does not have a lawful or legal bi-lateral contract with William Michael Johnson; and further 21. It is a fact that, Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, fact that alleged COUNTY OF BASTROP ET AL does not have legal relation with William Michael Johnson; and further 22. It is a fact that, Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, fact that William Michael Johnson is under no known legal obligation with or to the alleged COUNTY OF BASTROP ET AL ; and further DEFENDANT'S COUNTERCLAIM 3

4 23. It is a fact that, Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, fact that William Michael Johnson is under no legal obligation with or to the alleged Lee Gordon, alleged State Bar # ; and/or the MCCREARY, VESELKA, BRAGG & ALLEN, P.C. ; and further 24. It is a fact that, Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, fact that William Michael Johnson is not represented by the alleged Lee Gordon, alleged State Bar # ; or the MCCREARY, VESELKA, BRAGG & ALLEN, P.C. ; and further 25. It is a fact that, Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, BRAGG & ALLEN, P.C. have continued to perpetuate this abuse of process, conspiracy, malicious prosecution, wrongful attachment, conversion, common-law fraud, intentional infliction of emotional distress, invasion of privacy, nuisance, trespass and trespass to real property fraud upon the court, for the express purpose of obtaining the power of the court to assist them in unlawful trespass and uncompensated taking of William Michael Johnson s recorded and posted private property; and further 26. Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, BRAGG & ALLEN, P.C. have made false statements on the record of this 9842 case; and further 27. Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, BRAGG & ALLEN, P.C. are attempting to circumvent the plain language of the law by using the power of this court for their personal gain; and further 28. the alleged COUNTY OF BASTROP ET AL has not suffered any damage caused by William Michael Johnson; and further 29. Lee Gordon, alleged State Bar # ; and / or MCCREARY, VESELKA, BRAGG & ALLEN, P.C. have not suffered any damages caused by William Michael Johnson and have fraudulently brought this action only to seek personal gain from William Michael Johnson; therefore and further CAUSE ONE - Intentional Violation and Commission of Common Law Torts 30. William Michael Johnson, aggrieved party, reiterates and incorporates by reference all preceding DEFENDANT'S COUNTERCLAIM 4

5 31. the alleged COUNTY OF BASTROP ET AL and Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, BRAGG & ALLEN, P.C. intentionally perpetrated tort against William Michael Johnson, and aided and abetted each other in such wrongful acts -- these acts inflicted great and irreparable harm upon William Michael Johnson; and the CAUSE SIX - Defamation of Character-Slander 32. William Michael Johnson, aggrieved party, reiterates and incorporates by reference all preceding 33. the alleged COUNTY OF BASTROP and Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, BRAGG & ALLEN, P.C. through their actions and statements, including but not limited to those actions and statements listed in the originating complaint and this counterclaim, libeled, slandered and defamed the good character of and caused great and irreparable harm to the private man William Michael Johnson by the unauthorized use of the private and copyright trade name WILLIAM MICHAEL JOHNSON after being duly noticed not to do so, to wit; a. instigating, publishing and causing to be published the action with b. negligence; and c. malice; and with d. apparent intent for personal gain and enrichment; and the e. the statements written in the original complaint and filed into the public records, and transmitted into the community by the alleged COUNTY OF BASTROP and Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, BRAGG & ALLEN, P.C. caused and are causing great, irreparable and lasting harm to the private man William Michael Johnson; and the CAUSE EIGHT - False Reporting to Court 34. William Michael Johnson, aggrieved party, reiterates and incorporates by reference all preceding DEFENDANT'S COUNTERCLAIM 5

6 35. the attorney(s) in this instant matter knowingly and willfully reported inaccurate and false information to this Court concerning the private man William Michael Johnson for the direct purpose of enriching themselves while causing great and irreparable harm to the private man William Michael Johnson; and the CAUSE NINE - Invasion of Privacy 36. William Michael Johnson, aggrieved party, reiterates and incorporates by reference all preceding 37. Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, BRAGG & ALLEN, P.C., et al, through their actions and statements, engaged in wrongful acts that constitute an unwarranted invasion and trespass of William Michael Johnson s privacy; and the CAUSE TWELVE - Malicious Prosecution 38. William Michael Johnson, aggrieved party, reiterates and incorporates by reference all preceding 39. as a result of the alleged COUNTY OF BASTROP, Lee Gordon, alleged State Bar # ; and MCCREARY, VESELKA, BRAGG & ALLEN, P.C. s malicious prosecution inflicted upon William Michael Johnson emotional distress during the time frame commencing about the month of February in the year 2007 A.D. till now for a. the apparent sole purpose of pressuring William Michael Johnson to unwittingly surrender his private property; and the DEMAND FOR RELIEF WHEREFORE, I, William Michael Johnson, aggrieved party, hereby DEMAND a full lawful trial by jury so that this honorable court can grant the following relief on all causes contained in the answer which does include this counterclaim, and I, William Michael Johnson, demand from COUNTY OF BASTROP ET AL, Lee Gordon, alleged State Bar # ; and the MCCREARY, VESELKA, BRAGG & ALLEN, P.C. each individually damages in the amount of $5, (five thousand dollars and 00/cents - US silver species), punitive damages from each in the amount of $3, (three thousand dollars and no/cents - US silver species), all bonds relating, costs, appeal costs, collection costs, any and all other costs relating as may occur and all other additional relief as may be provided DEFENDANT'S COUNTERCLAIM 6

7 by a jury and / or further relief, special or general, legal or equitable that the Court or Jury may grant as may be shown to be justly entitled; and lastly release the Order of the Court to William Michael Johnson. This court is on notice: no ex parte meetings or rulings in this matter. Respectfully submitted by order of William Michael Johnson. DATED this day of May in the year A.D William Michael Johnson, sui juris, unrepresented on the land 191 Duck Pond Road c/o Post Office Box 366 McDade, Bastrop county Texas usa State of Texas VERIFICATION County: Bastrop Before me, a notary public, on this day of May, 2007 personally appeared William Michael Johnson, known to me to be the person whose name is subscribed to the foregoing. (L.S.) Notary Public in and for the State of Texas My Commission Expires DEFENDANT'S COUNTERCLAIM 7

8 CERTIFICATE OF SERVICE Lee Gordon, State Bar # MCCREARY, VESELKA, BRAGG & ALLEN, P.C. 700 Jeffrey Way, Suite 100 Round Rock, Texas MCCREARY, VESELKA, BRAGG, & ALLEN, P.C. registered agent, Harvey M. Allen 700 Jeffrey Way, Suite 100 Round Rock, Texas COUNTY OF BASTROP registered agent not known DEFENDANT'S COUNTERCLAIM 8

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