BALLI FAMILY HERITAGE, LLC
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January 19, 2002

NOTICE: To all the heirs of Jose Manuel Ballí Villarreal
RE: Cause No. 1261; The John G. and Marie Stella Memorial Foundation v. Sylvia Menchaca Ballí Aguilera, In the 105th District Court of Kenedy County, Texas.

 

Hearing Confirmed

Two hearing are set for January 22, 2002 in the Nueces County Courthouse in Corpus Christi. The address is 901 Leopard and the hearings will take place in the first floor courtroom.

The first hearing starts at 10:00 a.m. and involves the following:

  1. Our Motion to Compel the Kenedy Foundation to answer the interrogatories and requests for production needed to prove that in addition to Kenedy County, we cannot get a fair trial in either Kleberg or Nueces County;


  2. Our Motion for a Protective Order to prevent the Kenedy Foundation from taking depositions of certain family members including myself, until after the Motion to Change Venue has been decided. We are keeping the focus on getting the case moved from Kenedy County to a county where we can get a fair trial;


  3. Our Motion for New Scheduling Order to get back the time we lost caused by the Kenedy Foundation's delay in responding to our discovery requests as well as other things done to delay the case;


  4. The Kenedy Foundation's motion to add all "unknown and unborn" heirs of Jose Manuel Balli Villarreal to this lawsuit. If granted, any heirs who have not already gotten involved will be sued in the newspaper in Kingsville, Texas! Any primary heirs who have not already done so should immediately hire an attorney;


  5. The Kenedy Foundation's motions to compel the depositions of Gloria Munoz Gibney, Joe Balli and myself; and


  6. The Kenedy Foundation's motion to compel the Delia Pina Flores group to respond to discovery. This group recently hired our primo, Ballí-Patton to fight for them, which makes the fourth lawyer in the case to refer his clients to Hector Cárdenas and more are in the process of hiring him.

    The second hearing starts at 1:00 p.m. and involves:


  7. Our Motion for Special Exceptions, which is an attack on the Kenedy Foundation's defective paperwork. They sued us but they have delayed the case by: (1) at the first hearing on this Motion representing to the court that they would file amended paperwork within 30 days and not doing so until 98 days later; and (2) harassing the family by re-suing almost 500 heirs after the deadline to add new parties to the lawsuit.

The most important part of the hearing is our Motion to Compel and our Motion for Protection. If you wish to attend you may, but seating will be very limited.

It is an exciting time for our family because we are finally united and organized. I would like to ask you to pray for the person whose hard work has made this all possible, our primo, Hector Cárdenas. Pray that the Lord continues to guide him and to give him the strength and wisdom to make the Lord's plan for us a reality.

In the meantime, we are still looking for documents and witness to help us win the case. If one of your relatives has documents or remembers anything about La Barreta they should immediately contact myself or any of the officers of Ballí Family Heritage.

Please continue to pray for justice.

Respectfully yours,
Fred B. Ballí