STATE OF GEORGIA MICHAEL L LOWE )
) Plaintiff ) v )
) ELISA L SMITH )
) Defendant )
IN THE SUPERIOR COURT OF PAULDING COUNTY
Certificate of Service
IN RE MARTIN ENRIQUE V ALBUENA SANCTIONS BEARING
COMES NOW Elisa L Lowe and certifies that she has filed the following documents and pleadings in the above-captioned case and shows that she has mailed via first class mail copies ofsaid pleadings to Martin Valubena attorney ofrecord for the Plaintiff
VOLUNTARY DISMISSAL WITHOUT PREJUDICE OF CLAIM FOR HEARING AND SANCTIONS AGAINST MARTIN ENRIQUE V ALBUENA AS DIRECTED BY THE COURT OF APPEALS OF GEORGIA IN LOWE V LOWE
Martin Enrique Valubena 113 Village Walk Suite B PO Box 1125 Dallas Georgia 30132 So Certified this 3 day ofApril 2012
Pro Se Former Defendant 279 Crossroads Estates Drive Newnan GA 30265 (404) 704-7058
-0IN THE SUPERIOR COURT OF PAULDING COUNTY ~ ~-MICHAEL L LOWE
Plaintiff v
ELISA M LOWE
Defendant
STATE OF GEORGIA ) ) ) ) CIVIL ACTION FILE ) NO08-CV-1124-JO ) ) )
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IN RE MARTIN ENRIQUE VALBUENA SANCTIONS HEARING
VOLUNTARY DISMISSAL WITHOUT PREJUDICE OF CLAIM FOR HEARING AND SANCTIONS AGAINST MARTIN ENRIQUE VALBUENA AS DIRECTED BY THE COURT OF APPEALS OF GEORGIA IN LOWE V LOWE
Comes now the former Defendant Elisa M Lowe and files this Voluntary Dismissal Without Prejudice ofClaim for Hearing and Sanctions Against Martin Enrique Valbuena as Directed by the Court of Appeals of Georgia in Lowe V Lowe as follows
Your former Defendant Elisa M Lowe acting pro se did file 4 Motions with the Paulding Superior Court Judge James Osborne presiding providing evidence and supporting case law that this Honorable Court did not have jurisdiction in the above-referenced matter
On February 42011 this Honorable Court Judge James Osborne presiding was presented with official court transcripts from a contempt and jurisdictional hearing before Coweta Superior Court Judge Quillian Baldwin on January 6 2011
The official court transcript presented to Judge Osborne by oral argument and filed pleadings showed that Coweta Superior Court Judge Baldwin chastised Martine Enrique Valbuena for maintaining two simultaneous custody actions in the Coweta and Paulding Superior Court
During the Jurisdiction Hearing in Coweta Superior Court Judge Quillian Baldwin a more senior and learned judge offered his opinion on the validity of the Paulding Custody action
THE COURT Its unfortunate that she didnt keep the 25 lawyer and its unfortunate if that happened that wasnt 15 1 appealed because thats just incorrect Thats just an 2 incorrect ruling 3 Theres no way for him to issue an order in that
4 county if the same case was pending in Coweta County
THE COURT Its unfortunate that she didnt keep the 25 lawyer and its unfortunate if that happened that wasnt 15 1 appealed because thats just incorrect Thats just an 2 incorrect ruling 3 Theres no way for him to issue an order in that 4 county if the same case was pending in Coweta County
Coweta Superior Court Judge Quillian Baldwin agreed with your former Defendant that she had been home-cooked by the Paulding Superior Court
On appeal ofthe above-captioned matter the Court ofAppeals ofGeorgia decided and ruled that the Paulding Superior Court had no jurisdiction in this matter (See Lowe v Lowe)
All judgments and orders issued by the Paulding Superior Court Judge James Osborne presiding were vacated and declared null and void
The Georgia tort of Malicious Prosecution (OGGA sect 51-7-40) is specifically designed to give redress to a Plaintiff against a judge that has acted without jurisdiction or authority and such exercise ofjurisdiction has harmed the Plaintiff
By ruling that Judge Osbornes actions were outside the jurisdiction and scope ofhis authority in this custody matter the Court of Appeals of Georgia disposed of the matter in favor of the Plaintiff and gave rise to a cause of action by your Plaintiff against Judge Osborne including but not limited to Malicious Prosecution and Interference with Custody Rights
Your Plaintiff intends to bring causes ofaction against each tort-feasor in this case including James Osborne individually
Judge Osborne has a personal and pecuniary interest in the outcome ofthe sanctions hearing against Martin Enrique Valbuena as he is a co-tort feasor for the malicious prosecution levied against your former Defendant Elisa M Lowe
On March 22 2012 your Plaintiff filed a Motion to Recuse Judge Osborne as Martin Enrique Valbuena is a judicial colleague and peer of Judge Osborne and the other Judges of the Paulding Superior Court
Judge Osborne dismissed your former Defendants Motion to Recuse for failure to submit a supporting affidavit
Judge Osborne obviously is more concerned about civil procedure than his reputation for fairness and honesty
However the basis for the motion was a matter ofwhich Judge Osborne has personal knowledge to wit That Martin Enrique Valbuena is a judicial peer as Pro Tern Superior Court Judge Chief Magistrate of Paulding County and Pro Tern Probate Judge of Paulding County
Judge Osborne has judicial notice knows and has actual knowledge that Martin Enrique Valbuena has been appointed as a Pro Tern Superior Court Judge to act in such emergency matters which may include but are not limited to ex parte family violence petitioner when violence petitions when the other five (5) regular or senior judges are unavailable (See Chief Judge Beavers appointment of Martin Enrique Valbuena to Superior Court Judge marked as Exhibits 12 amp 3)
Judicial Canon 3(E)(1) provides that judges shall disqualify in any proceeding in which their impartiality might reasonably be questioned
Judge James Osborne is a witness to the fraudulent and untrue statements made at the ex parte custody hearing by Valbuena and the Plaintiff
Judge Osborne failed to have recorded or transcribed or mark evidence that he considered in this one-sided hearing that gives rise to your former Defendants claim for tortious interference with child custody against both Valbuena and Judge Osborne
Moreover when a judge testifies as a witness a lawyer who regularly appears before the judge may be placed in the awkward position ofcross-examining the judge Ajudge may however testify when properly summoned Commentary to Judicial Canon 2B ofthe Georgia Code ofJudicial Conduct
Despite knowing that he is a witness probable defendant and a judge that improvidently acted without jurisdiction he refuses to recuse himself in this matter ofSanctions Hearing Against Martin Enrique Valbuena See ChiefJudge William F Lee Jrs January 212004 Order vacating ex parte custody relief granted to the former Plaintiff Michael L Lowe and marked as Attachment C)
For whatever reason Judge Osborne will not release said Sanctions Hearing to the Coweta Superior Court the court of continuing and exclusive jurisdiction over this matter
Your former Defendant shows that she will not receive a fair and impartial hearing before Paulding Superior Court with Judge James Osborne presiding
Required Recusal of Other Paulding Superior Court Judges
Paulding Superior Court Chief Judge Tonney S Beavers
Your former Defendant has no faith that she will receive a fair tria1 by any of the Judges of the Paulding Judicial Circuit where Martin Enrique Valbuena is involved and concerned
Chief Judge Tonney S Beavers has appointed Martin Enrique Valbuena to the level of Paulding Superior Court Judge on several occasions (Exhibits A Band C )
Chief Judge Tonney SBeavers was given notice ofthe Motion to Recuse via first class mail and the Motion to Recuse specifically requested that he intervene and assign a disinterested non-Paulding County Superior Court Judge to conduct this sanctions hearing (See Exhibit K)
The Court ofAppeals noted the special favors ChiefJudge Tonney S Beavers bestows upon judicial peer Martin Enrique Valbuena in Union Maintenance Inc v Wilson 595 SE 2d 376 (2004)
The Court ofAppeals noted that ChiefJudge Beavers conducted a trial and Mr Valhuenas client lost and on January 292003 ChiefJudge Beavers entered judgment against him in the amount of $2521819 Chief Judge Beavers signed the hand-written the $2521819 judgment and found Mr Valbuenas clients Answer to be Untrue (See Exhihit E) Thereafter the Answer in the case was taken from the case file and all evidence of its entry with the Clerk of Clerk had been erased Subsequently Martin Enrique Valbuena presented a default judgment to Chief Judge Beavers in an ex parte hearing reducing the judgment to $50 The opposing attorney who had no notice ofthe hearing or received call from the Court requesting his presence took great pains to find a Paulding Clerk red-stamp copy ofthe missing Answer ChiefJudge Beavers certified the found red stamp Answer as authentic but refused to vacate Valbuena s fraudulently obtained default judgment The case was appealed and the Court of Appeals of Georgia overturned Chief Judge Beavers found against Martin Valbuena and his client and reinstated the $2521819 judgment Thereafter Wilson then filed bankruptcy erasing the long fought debt
ChiefJudge Beavers had no legal authority to change his judgment rendered at trial and reduce the judgment amount from $2521819 to a default judgment of $50
Without authority orjurisdiction ChiefJudge Tonny S Beavers reduced the trial judgment whether by fraud or favor for Martin Enrique Valbuena on behalf of his previously impeached and untruthful client Charles Wilson (See Attachment E)
Paulding Superior Court Judge Kenneth G Vinson
On March 9 2012 the Court ofAppeals ofGeorgia found in favor ofElisa M Lowe and found that Paulding County had no jurisdiction whatsoever in the Lowes custody matters
The holding directed monetary sanctions to be considered against Martin Enrique Valbuena for his misdeeds in the Paulding and Coweta Superior Courts
The Lowe v Lowe holding also allowed your former Defendant to pursue and assert a host ofother torts against Valbuena including but not limited to false arrest false imprisonment tortious interference with custody abuse ofprocess and malicious prosecution
On March 8 2012 in an effort to shield personal property and assets from judgment and attachment Martin Enrique Valbuena and his wife Jennifer M Haverty Valbuena did file a Separate Maintenance Action in the Paulding Superior Court12-CV-926-KV
Reminiscent of the Judge OsborneGlen Richards sealed divorce proceedings Judge Vinson was presented with the Separate Maintenance Petition
Four days after the initial filing of the Petition Judge Vinson did execute and issue an Decree for Separate Maintenance giving Jennifer M Haverty Valbuena certain rights of marital property and extinguishing Martin Enrique Valbuenas property interests in certain marital properties (See Exhibit J)
Jennifer M Haverty Valbuena was not represented by legal counsel against her Judge husband Martin Enrique Valbuena
The parties did not file the required Domestic Relations Filing Information as required by s Financial Affidavit with the Paulding Clerk of Court as required by OCGA sect 9-11-133
The parties failed to file the following required documents with the Clerk of Court
1) Domestic Relations Financial Affidavits
2) All federal and state income tax returns gift tax returns and intangible and personal property tax returns filed by the party or on the partys behalffor the past three (3) years
3) IRS forms W -2 1099 and K -1 forms for the past year if the income tax return for that year has not been prepared Also if such income tax return has not been prepared a year-ending pay stub received from the partys employer should be provided
4)Pay stubs or other evidence ofearned income for the twelve (12) months prior to the filing of the action
5)A statement by the producing party identifying the amount and source of all income received from all sources during the twelve (12) months preceding the filing of this action if same is not reflected on the pay stubs produced
6)Allloan applications and financial statements prepared or used within the three (3) years preceding the filing date of this action whether used for the purpose of obtaining or attempting to obtain credit for any other purpose
7) The most recent statement for any liquid fund assets including but not limited to profit-sharing 401-K money market stock and securities bonds accounts retirement and pension plan
8) Corporate partnership and trust tax returns for the last three (3) years if the producing party has an interest in a corporation partnership or trust greater than or equal to thirty (30) percent
9) Any Court Orders directing a party to payor receive spousal or child support even ifreceived from a third party
The parties were warned that Any Materially False Statement Knowingly Made in These Documents with the Intent to Defraud or Mislead Shall Subject Me to the Penalty for Perjury and May Be Considered a Fraud upon the Court
In the Paulding Superior Court the Valbuenas were not required to file the required financial information every other litigant must file in a domestic relations case
The parties are not obligated to pay child support to one another
Martin Enrique Valbuena was granted primary physical and joint legal custody ofthe minor children of the parties with the wife having secondary physical custody and joint legal custody
Jennifer M Haverty Valbuena filed the Petition for Separate Maintenance on March 8 2012
The Clerk ofPaulding County Superior Court filed the Petitioner and Summons on March 8 2012
Martin Valbuena acknowledged personal service of Jennifer Valbuenas Petition for Separate Maintenance on March 52012 three days before it was filed with the Clerk ofCourt and assigned a civil file action number
Judge Vinson executed the Decree ofSeparate Maintenance on March 12 20 I 0 coinciding with the delivery date ofyour former Defendants Intent to Sue letter sent to Martin Enrique Valbuena
As late as March 30 2012 at 529 pm Jennifer M Haverty Valbuena maintained on her facebook page that I am married to an incredible man (See Exhibit F)
On April 12012 Jennifer M Haverty Valbuena posted a photograph on her facebook page of a smiling Jennifer and Martin Enrique Valbuena together at the Atlanta restaurant N ava (See Exhibit G)
Not only was this Separate Maintenance action rushed through the Paulding Court system it appears the bona fide state of separation is a sham
By entering the Order for Separate Maintenance Judge Vinson did violate JQC Opinion 220
OPINION NO 220 Docket No 97-78 states as follows A sitting Superior Court Judge in a multi-judge circuit while expressly denying any bias prejudice or unfairness nevertheless requests an opinion on the following question Should a judge in a particular circuit ever preside or sit in judgment in the divorce ofanother judge from the same circuit or any matter relating to it contested or uncontested The response cites Canons 1 2 amp 3 ofthe Code ofJudicial Conduct cites case law of King v State 246 Ga 386 (1980) Wallace v Wallace 352 So2d 136(1977) and Commonwealth v Armor 398 A2d 173(1978) and ends with the following paragraph Simply stated the public must believe in the absolute integrity and impartiality of its judges and it is the obligation of this Commission to support and encourage such belief Consequently even without a showing ofactual bias prejudice or unfairness and regardless ofthe merits or timeliness ofa Motion to Recuse this Commission concludes that it is inappropriate for any trial court judge to preside in any action wherein one ofthe parties holds a judicial office on the same or any other court which sits in the same circuit
Voluntary Dismissal Without Prejudice
Your fonner Defendant cannot receive a fair hearing before any ofthe sitting or senior judges ofthe Paulding Judicial Circuit Judge James Osborne has presided over the entire above-captioned and vacated case Judge Osborne refuses to recuse himself Judge Osborne has taken my children from my custody without jurisdiction Martin Enrique Valbuenahad me jailed ChiefJudge Beavers has granted favors to Martin Enrique Valbuena Judge Vinson granted a Separate Maintenance Order taking custody rights from Ms Valbuena knowing she had disparate legal knowledge compared to her husband Chief Magistrate Probate Judge Pro Tern and Pro tern Superior Court Judge Martin Enrique Valbuena Jennifer Valbuenas Facebook postings after the Separate Maintenance Order raise questions to the sincerity ofthe property division between the parties Mr Valbuena is too ingrained a part of and politically connected and in the Paulding Judicial system for your fonner Defendant to prevail on the merits ofher claims and your fonner Defendant wishes to end this Paulding County horne-cooking and assert her tort claims in an appropriate venue and forum
As such your Plaintiff respectfully voluntarily dismisses without prejudice her claim for Sanctions Against Martin Enrique Valbuena and foregoes the hearing directed by the Court of Appeals ofGeorgia in Lowe v Lowe Your fonner Defendant will assert her claims against Martin Enrique Valbuena and Judge James Osborne in a more appropriate and fair forum This sanctions hearing and the resulting monetary sanctions cannot begin to compensate your fonner Defendant for the damages caused by the above-described tort-feasors
ProSe 279 Crossroads Estates Road Newnan GA 30265 (404) 704-7058
EXHIBIT A
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER APPOINTING MAGISTRATE JUDGE TO HANDIJR
EMERGENCY MATIERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to eX parte family violence petitions This appoinunent is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
July 26 2010 through and including July 302010
SO ORDERED this 16mday ofJuly 2010
Marrin Enrique Valbuena Judge 0 t
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EXHIBIT B
STATE OF GEORGIA
ORDER APPOINTIlG MAGISTRATE JlDGE TO IIA~DLE
EMERGENCY MATTERS I~ SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after dtlc diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is bereby appointed to act in such emergency matters which may
include but are not limited to ex pane family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCOA Scction 15-1-91 and is effective
January 192010 through and including January 222010
SO ORDERED this 13th day ofJanuary 2010
CONSENTED TO
~cbb Martin Enrique Valbuena Judge Magistrate Court ofPaulding County
EXHIBT C
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER AfPOINTlNG MAGISTRATE JUDGE TO HANDLE
EMERGENCY MATTERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to ex parte family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
January 21 2009 through and including January 232009
SO ORDERED this IlJjday ofJanuary 2009
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EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
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-0IN THE SUPERIOR COURT OF PAULDING COUNTY ~ ~-MICHAEL L LOWE
Plaintiff v
ELISA M LOWE
Defendant
STATE OF GEORGIA ) ) ) ) CIVIL ACTION FILE ) NO08-CV-1124-JO ) ) )
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IN RE MARTIN ENRIQUE VALBUENA SANCTIONS HEARING
VOLUNTARY DISMISSAL WITHOUT PREJUDICE OF CLAIM FOR HEARING AND SANCTIONS AGAINST MARTIN ENRIQUE VALBUENA AS DIRECTED BY THE COURT OF APPEALS OF GEORGIA IN LOWE V LOWE
Comes now the former Defendant Elisa M Lowe and files this Voluntary Dismissal Without Prejudice ofClaim for Hearing and Sanctions Against Martin Enrique Valbuena as Directed by the Court of Appeals of Georgia in Lowe V Lowe as follows
Your former Defendant Elisa M Lowe acting pro se did file 4 Motions with the Paulding Superior Court Judge James Osborne presiding providing evidence and supporting case law that this Honorable Court did not have jurisdiction in the above-referenced matter
On February 42011 this Honorable Court Judge James Osborne presiding was presented with official court transcripts from a contempt and jurisdictional hearing before Coweta Superior Court Judge Quillian Baldwin on January 6 2011
The official court transcript presented to Judge Osborne by oral argument and filed pleadings showed that Coweta Superior Court Judge Baldwin chastised Martine Enrique Valbuena for maintaining two simultaneous custody actions in the Coweta and Paulding Superior Court
During the Jurisdiction Hearing in Coweta Superior Court Judge Quillian Baldwin a more senior and learned judge offered his opinion on the validity of the Paulding Custody action
THE COURT Its unfortunate that she didnt keep the 25 lawyer and its unfortunate if that happened that wasnt 15 1 appealed because thats just incorrect Thats just an 2 incorrect ruling 3 Theres no way for him to issue an order in that
4 county if the same case was pending in Coweta County
THE COURT Its unfortunate that she didnt keep the 25 lawyer and its unfortunate if that happened that wasnt 15 1 appealed because thats just incorrect Thats just an 2 incorrect ruling 3 Theres no way for him to issue an order in that 4 county if the same case was pending in Coweta County
Coweta Superior Court Judge Quillian Baldwin agreed with your former Defendant that she had been home-cooked by the Paulding Superior Court
On appeal ofthe above-captioned matter the Court ofAppeals ofGeorgia decided and ruled that the Paulding Superior Court had no jurisdiction in this matter (See Lowe v Lowe)
All judgments and orders issued by the Paulding Superior Court Judge James Osborne presiding were vacated and declared null and void
The Georgia tort of Malicious Prosecution (OGGA sect 51-7-40) is specifically designed to give redress to a Plaintiff against a judge that has acted without jurisdiction or authority and such exercise ofjurisdiction has harmed the Plaintiff
By ruling that Judge Osbornes actions were outside the jurisdiction and scope ofhis authority in this custody matter the Court of Appeals of Georgia disposed of the matter in favor of the Plaintiff and gave rise to a cause of action by your Plaintiff against Judge Osborne including but not limited to Malicious Prosecution and Interference with Custody Rights
Your Plaintiff intends to bring causes ofaction against each tort-feasor in this case including James Osborne individually
Judge Osborne has a personal and pecuniary interest in the outcome ofthe sanctions hearing against Martin Enrique Valbuena as he is a co-tort feasor for the malicious prosecution levied against your former Defendant Elisa M Lowe
On March 22 2012 your Plaintiff filed a Motion to Recuse Judge Osborne as Martin Enrique Valbuena is a judicial colleague and peer of Judge Osborne and the other Judges of the Paulding Superior Court
Judge Osborne dismissed your former Defendants Motion to Recuse for failure to submit a supporting affidavit
Judge Osborne obviously is more concerned about civil procedure than his reputation for fairness and honesty
However the basis for the motion was a matter ofwhich Judge Osborne has personal knowledge to wit That Martin Enrique Valbuena is a judicial peer as Pro Tern Superior Court Judge Chief Magistrate of Paulding County and Pro Tern Probate Judge of Paulding County
Judge Osborne has judicial notice knows and has actual knowledge that Martin Enrique Valbuena has been appointed as a Pro Tern Superior Court Judge to act in such emergency matters which may include but are not limited to ex parte family violence petitioner when violence petitions when the other five (5) regular or senior judges are unavailable (See Chief Judge Beavers appointment of Martin Enrique Valbuena to Superior Court Judge marked as Exhibits 12 amp 3)
Judicial Canon 3(E)(1) provides that judges shall disqualify in any proceeding in which their impartiality might reasonably be questioned
Judge James Osborne is a witness to the fraudulent and untrue statements made at the ex parte custody hearing by Valbuena and the Plaintiff
Judge Osborne failed to have recorded or transcribed or mark evidence that he considered in this one-sided hearing that gives rise to your former Defendants claim for tortious interference with child custody against both Valbuena and Judge Osborne
Moreover when a judge testifies as a witness a lawyer who regularly appears before the judge may be placed in the awkward position ofcross-examining the judge Ajudge may however testify when properly summoned Commentary to Judicial Canon 2B ofthe Georgia Code ofJudicial Conduct
Despite knowing that he is a witness probable defendant and a judge that improvidently acted without jurisdiction he refuses to recuse himself in this matter ofSanctions Hearing Against Martin Enrique Valbuena See ChiefJudge William F Lee Jrs January 212004 Order vacating ex parte custody relief granted to the former Plaintiff Michael L Lowe and marked as Attachment C)
For whatever reason Judge Osborne will not release said Sanctions Hearing to the Coweta Superior Court the court of continuing and exclusive jurisdiction over this matter
Your former Defendant shows that she will not receive a fair and impartial hearing before Paulding Superior Court with Judge James Osborne presiding
Required Recusal of Other Paulding Superior Court Judges
Paulding Superior Court Chief Judge Tonney S Beavers
Your former Defendant has no faith that she will receive a fair tria1 by any of the Judges of the Paulding Judicial Circuit where Martin Enrique Valbuena is involved and concerned
Chief Judge Tonney S Beavers has appointed Martin Enrique Valbuena to the level of Paulding Superior Court Judge on several occasions (Exhibits A Band C )
Chief Judge Tonney SBeavers was given notice ofthe Motion to Recuse via first class mail and the Motion to Recuse specifically requested that he intervene and assign a disinterested non-Paulding County Superior Court Judge to conduct this sanctions hearing (See Exhibit K)
The Court ofAppeals noted the special favors ChiefJudge Tonney S Beavers bestows upon judicial peer Martin Enrique Valbuena in Union Maintenance Inc v Wilson 595 SE 2d 376 (2004)
The Court ofAppeals noted that ChiefJudge Beavers conducted a trial and Mr Valhuenas client lost and on January 292003 ChiefJudge Beavers entered judgment against him in the amount of $2521819 Chief Judge Beavers signed the hand-written the $2521819 judgment and found Mr Valbuenas clients Answer to be Untrue (See Exhihit E) Thereafter the Answer in the case was taken from the case file and all evidence of its entry with the Clerk of Clerk had been erased Subsequently Martin Enrique Valbuena presented a default judgment to Chief Judge Beavers in an ex parte hearing reducing the judgment to $50 The opposing attorney who had no notice ofthe hearing or received call from the Court requesting his presence took great pains to find a Paulding Clerk red-stamp copy ofthe missing Answer ChiefJudge Beavers certified the found red stamp Answer as authentic but refused to vacate Valbuena s fraudulently obtained default judgment The case was appealed and the Court of Appeals of Georgia overturned Chief Judge Beavers found against Martin Valbuena and his client and reinstated the $2521819 judgment Thereafter Wilson then filed bankruptcy erasing the long fought debt
ChiefJudge Beavers had no legal authority to change his judgment rendered at trial and reduce the judgment amount from $2521819 to a default judgment of $50
Without authority orjurisdiction ChiefJudge Tonny S Beavers reduced the trial judgment whether by fraud or favor for Martin Enrique Valbuena on behalf of his previously impeached and untruthful client Charles Wilson (See Attachment E)
Paulding Superior Court Judge Kenneth G Vinson
On March 9 2012 the Court ofAppeals ofGeorgia found in favor ofElisa M Lowe and found that Paulding County had no jurisdiction whatsoever in the Lowes custody matters
The holding directed monetary sanctions to be considered against Martin Enrique Valbuena for his misdeeds in the Paulding and Coweta Superior Courts
The Lowe v Lowe holding also allowed your former Defendant to pursue and assert a host ofother torts against Valbuena including but not limited to false arrest false imprisonment tortious interference with custody abuse ofprocess and malicious prosecution
On March 8 2012 in an effort to shield personal property and assets from judgment and attachment Martin Enrique Valbuena and his wife Jennifer M Haverty Valbuena did file a Separate Maintenance Action in the Paulding Superior Court12-CV-926-KV
Reminiscent of the Judge OsborneGlen Richards sealed divorce proceedings Judge Vinson was presented with the Separate Maintenance Petition
Four days after the initial filing of the Petition Judge Vinson did execute and issue an Decree for Separate Maintenance giving Jennifer M Haverty Valbuena certain rights of marital property and extinguishing Martin Enrique Valbuenas property interests in certain marital properties (See Exhibit J)
Jennifer M Haverty Valbuena was not represented by legal counsel against her Judge husband Martin Enrique Valbuena
The parties did not file the required Domestic Relations Filing Information as required by s Financial Affidavit with the Paulding Clerk of Court as required by OCGA sect 9-11-133
The parties failed to file the following required documents with the Clerk of Court
1) Domestic Relations Financial Affidavits
2) All federal and state income tax returns gift tax returns and intangible and personal property tax returns filed by the party or on the partys behalffor the past three (3) years
3) IRS forms W -2 1099 and K -1 forms for the past year if the income tax return for that year has not been prepared Also if such income tax return has not been prepared a year-ending pay stub received from the partys employer should be provided
4)Pay stubs or other evidence ofearned income for the twelve (12) months prior to the filing of the action
5)A statement by the producing party identifying the amount and source of all income received from all sources during the twelve (12) months preceding the filing of this action if same is not reflected on the pay stubs produced
6)Allloan applications and financial statements prepared or used within the three (3) years preceding the filing date of this action whether used for the purpose of obtaining or attempting to obtain credit for any other purpose
7) The most recent statement for any liquid fund assets including but not limited to profit-sharing 401-K money market stock and securities bonds accounts retirement and pension plan
8) Corporate partnership and trust tax returns for the last three (3) years if the producing party has an interest in a corporation partnership or trust greater than or equal to thirty (30) percent
9) Any Court Orders directing a party to payor receive spousal or child support even ifreceived from a third party
The parties were warned that Any Materially False Statement Knowingly Made in These Documents with the Intent to Defraud or Mislead Shall Subject Me to the Penalty for Perjury and May Be Considered a Fraud upon the Court
In the Paulding Superior Court the Valbuenas were not required to file the required financial information every other litigant must file in a domestic relations case
The parties are not obligated to pay child support to one another
Martin Enrique Valbuena was granted primary physical and joint legal custody ofthe minor children of the parties with the wife having secondary physical custody and joint legal custody
Jennifer M Haverty Valbuena filed the Petition for Separate Maintenance on March 8 2012
The Clerk ofPaulding County Superior Court filed the Petitioner and Summons on March 8 2012
Martin Valbuena acknowledged personal service of Jennifer Valbuenas Petition for Separate Maintenance on March 52012 three days before it was filed with the Clerk ofCourt and assigned a civil file action number
Judge Vinson executed the Decree ofSeparate Maintenance on March 12 20 I 0 coinciding with the delivery date ofyour former Defendants Intent to Sue letter sent to Martin Enrique Valbuena
As late as March 30 2012 at 529 pm Jennifer M Haverty Valbuena maintained on her facebook page that I am married to an incredible man (See Exhibit F)
On April 12012 Jennifer M Haverty Valbuena posted a photograph on her facebook page of a smiling Jennifer and Martin Enrique Valbuena together at the Atlanta restaurant N ava (See Exhibit G)
Not only was this Separate Maintenance action rushed through the Paulding Court system it appears the bona fide state of separation is a sham
By entering the Order for Separate Maintenance Judge Vinson did violate JQC Opinion 220
OPINION NO 220 Docket No 97-78 states as follows A sitting Superior Court Judge in a multi-judge circuit while expressly denying any bias prejudice or unfairness nevertheless requests an opinion on the following question Should a judge in a particular circuit ever preside or sit in judgment in the divorce ofanother judge from the same circuit or any matter relating to it contested or uncontested The response cites Canons 1 2 amp 3 ofthe Code ofJudicial Conduct cites case law of King v State 246 Ga 386 (1980) Wallace v Wallace 352 So2d 136(1977) and Commonwealth v Armor 398 A2d 173(1978) and ends with the following paragraph Simply stated the public must believe in the absolute integrity and impartiality of its judges and it is the obligation of this Commission to support and encourage such belief Consequently even without a showing ofactual bias prejudice or unfairness and regardless ofthe merits or timeliness ofa Motion to Recuse this Commission concludes that it is inappropriate for any trial court judge to preside in any action wherein one ofthe parties holds a judicial office on the same or any other court which sits in the same circuit
Voluntary Dismissal Without Prejudice
Your fonner Defendant cannot receive a fair hearing before any ofthe sitting or senior judges ofthe Paulding Judicial Circuit Judge James Osborne has presided over the entire above-captioned and vacated case Judge Osborne refuses to recuse himself Judge Osborne has taken my children from my custody without jurisdiction Martin Enrique Valbuenahad me jailed ChiefJudge Beavers has granted favors to Martin Enrique Valbuena Judge Vinson granted a Separate Maintenance Order taking custody rights from Ms Valbuena knowing she had disparate legal knowledge compared to her husband Chief Magistrate Probate Judge Pro Tern and Pro tern Superior Court Judge Martin Enrique Valbuena Jennifer Valbuenas Facebook postings after the Separate Maintenance Order raise questions to the sincerity ofthe property division between the parties Mr Valbuena is too ingrained a part of and politically connected and in the Paulding Judicial system for your fonner Defendant to prevail on the merits ofher claims and your fonner Defendant wishes to end this Paulding County horne-cooking and assert her tort claims in an appropriate venue and forum
As such your Plaintiff respectfully voluntarily dismisses without prejudice her claim for Sanctions Against Martin Enrique Valbuena and foregoes the hearing directed by the Court of Appeals ofGeorgia in Lowe v Lowe Your fonner Defendant will assert her claims against Martin Enrique Valbuena and Judge James Osborne in a more appropriate and fair forum This sanctions hearing and the resulting monetary sanctions cannot begin to compensate your fonner Defendant for the damages caused by the above-described tort-feasors
ProSe 279 Crossroads Estates Road Newnan GA 30265 (404) 704-7058
EXHIBIT A
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER APPOINTING MAGISTRATE JUDGE TO HANDIJR
EMERGENCY MATIERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to eX parte family violence petitions This appoinunent is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
July 26 2010 through and including July 302010
SO ORDERED this 16mday ofJuly 2010
Marrin Enrique Valbuena Judge 0 t
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EXHIBIT B
STATE OF GEORGIA
ORDER APPOINTIlG MAGISTRATE JlDGE TO IIA~DLE
EMERGENCY MATTERS I~ SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after dtlc diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is bereby appointed to act in such emergency matters which may
include but are not limited to ex pane family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCOA Scction 15-1-91 and is effective
January 192010 through and including January 222010
SO ORDERED this 13th day ofJanuary 2010
CONSENTED TO
~cbb Martin Enrique Valbuena Judge Magistrate Court ofPaulding County
EXHIBT C
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER AfPOINTlNG MAGISTRATE JUDGE TO HANDLE
EMERGENCY MATTERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to ex parte family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
January 21 2009 through and including January 232009
SO ORDERED this IlJjday ofJanuary 2009
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EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
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4 county if the same case was pending in Coweta County
THE COURT Its unfortunate that she didnt keep the 25 lawyer and its unfortunate if that happened that wasnt 15 1 appealed because thats just incorrect Thats just an 2 incorrect ruling 3 Theres no way for him to issue an order in that 4 county if the same case was pending in Coweta County
Coweta Superior Court Judge Quillian Baldwin agreed with your former Defendant that she had been home-cooked by the Paulding Superior Court
On appeal ofthe above-captioned matter the Court ofAppeals ofGeorgia decided and ruled that the Paulding Superior Court had no jurisdiction in this matter (See Lowe v Lowe)
All judgments and orders issued by the Paulding Superior Court Judge James Osborne presiding were vacated and declared null and void
The Georgia tort of Malicious Prosecution (OGGA sect 51-7-40) is specifically designed to give redress to a Plaintiff against a judge that has acted without jurisdiction or authority and such exercise ofjurisdiction has harmed the Plaintiff
By ruling that Judge Osbornes actions were outside the jurisdiction and scope ofhis authority in this custody matter the Court of Appeals of Georgia disposed of the matter in favor of the Plaintiff and gave rise to a cause of action by your Plaintiff against Judge Osborne including but not limited to Malicious Prosecution and Interference with Custody Rights
Your Plaintiff intends to bring causes ofaction against each tort-feasor in this case including James Osborne individually
Judge Osborne has a personal and pecuniary interest in the outcome ofthe sanctions hearing against Martin Enrique Valbuena as he is a co-tort feasor for the malicious prosecution levied against your former Defendant Elisa M Lowe
On March 22 2012 your Plaintiff filed a Motion to Recuse Judge Osborne as Martin Enrique Valbuena is a judicial colleague and peer of Judge Osborne and the other Judges of the Paulding Superior Court
Judge Osborne dismissed your former Defendants Motion to Recuse for failure to submit a supporting affidavit
Judge Osborne obviously is more concerned about civil procedure than his reputation for fairness and honesty
However the basis for the motion was a matter ofwhich Judge Osborne has personal knowledge to wit That Martin Enrique Valbuena is a judicial peer as Pro Tern Superior Court Judge Chief Magistrate of Paulding County and Pro Tern Probate Judge of Paulding County
Judge Osborne has judicial notice knows and has actual knowledge that Martin Enrique Valbuena has been appointed as a Pro Tern Superior Court Judge to act in such emergency matters which may include but are not limited to ex parte family violence petitioner when violence petitions when the other five (5) regular or senior judges are unavailable (See Chief Judge Beavers appointment of Martin Enrique Valbuena to Superior Court Judge marked as Exhibits 12 amp 3)
Judicial Canon 3(E)(1) provides that judges shall disqualify in any proceeding in which their impartiality might reasonably be questioned
Judge James Osborne is a witness to the fraudulent and untrue statements made at the ex parte custody hearing by Valbuena and the Plaintiff
Judge Osborne failed to have recorded or transcribed or mark evidence that he considered in this one-sided hearing that gives rise to your former Defendants claim for tortious interference with child custody against both Valbuena and Judge Osborne
Moreover when a judge testifies as a witness a lawyer who regularly appears before the judge may be placed in the awkward position ofcross-examining the judge Ajudge may however testify when properly summoned Commentary to Judicial Canon 2B ofthe Georgia Code ofJudicial Conduct
Despite knowing that he is a witness probable defendant and a judge that improvidently acted without jurisdiction he refuses to recuse himself in this matter ofSanctions Hearing Against Martin Enrique Valbuena See ChiefJudge William F Lee Jrs January 212004 Order vacating ex parte custody relief granted to the former Plaintiff Michael L Lowe and marked as Attachment C)
For whatever reason Judge Osborne will not release said Sanctions Hearing to the Coweta Superior Court the court of continuing and exclusive jurisdiction over this matter
Your former Defendant shows that she will not receive a fair and impartial hearing before Paulding Superior Court with Judge James Osborne presiding
Required Recusal of Other Paulding Superior Court Judges
Paulding Superior Court Chief Judge Tonney S Beavers
Your former Defendant has no faith that she will receive a fair tria1 by any of the Judges of the Paulding Judicial Circuit where Martin Enrique Valbuena is involved and concerned
Chief Judge Tonney S Beavers has appointed Martin Enrique Valbuena to the level of Paulding Superior Court Judge on several occasions (Exhibits A Band C )
Chief Judge Tonney SBeavers was given notice ofthe Motion to Recuse via first class mail and the Motion to Recuse specifically requested that he intervene and assign a disinterested non-Paulding County Superior Court Judge to conduct this sanctions hearing (See Exhibit K)
The Court ofAppeals noted the special favors ChiefJudge Tonney S Beavers bestows upon judicial peer Martin Enrique Valbuena in Union Maintenance Inc v Wilson 595 SE 2d 376 (2004)
The Court ofAppeals noted that ChiefJudge Beavers conducted a trial and Mr Valhuenas client lost and on January 292003 ChiefJudge Beavers entered judgment against him in the amount of $2521819 Chief Judge Beavers signed the hand-written the $2521819 judgment and found Mr Valbuenas clients Answer to be Untrue (See Exhihit E) Thereafter the Answer in the case was taken from the case file and all evidence of its entry with the Clerk of Clerk had been erased Subsequently Martin Enrique Valbuena presented a default judgment to Chief Judge Beavers in an ex parte hearing reducing the judgment to $50 The opposing attorney who had no notice ofthe hearing or received call from the Court requesting his presence took great pains to find a Paulding Clerk red-stamp copy ofthe missing Answer ChiefJudge Beavers certified the found red stamp Answer as authentic but refused to vacate Valbuena s fraudulently obtained default judgment The case was appealed and the Court of Appeals of Georgia overturned Chief Judge Beavers found against Martin Valbuena and his client and reinstated the $2521819 judgment Thereafter Wilson then filed bankruptcy erasing the long fought debt
ChiefJudge Beavers had no legal authority to change his judgment rendered at trial and reduce the judgment amount from $2521819 to a default judgment of $50
Without authority orjurisdiction ChiefJudge Tonny S Beavers reduced the trial judgment whether by fraud or favor for Martin Enrique Valbuena on behalf of his previously impeached and untruthful client Charles Wilson (See Attachment E)
Paulding Superior Court Judge Kenneth G Vinson
On March 9 2012 the Court ofAppeals ofGeorgia found in favor ofElisa M Lowe and found that Paulding County had no jurisdiction whatsoever in the Lowes custody matters
The holding directed monetary sanctions to be considered against Martin Enrique Valbuena for his misdeeds in the Paulding and Coweta Superior Courts
The Lowe v Lowe holding also allowed your former Defendant to pursue and assert a host ofother torts against Valbuena including but not limited to false arrest false imprisonment tortious interference with custody abuse ofprocess and malicious prosecution
On March 8 2012 in an effort to shield personal property and assets from judgment and attachment Martin Enrique Valbuena and his wife Jennifer M Haverty Valbuena did file a Separate Maintenance Action in the Paulding Superior Court12-CV-926-KV
Reminiscent of the Judge OsborneGlen Richards sealed divorce proceedings Judge Vinson was presented with the Separate Maintenance Petition
Four days after the initial filing of the Petition Judge Vinson did execute and issue an Decree for Separate Maintenance giving Jennifer M Haverty Valbuena certain rights of marital property and extinguishing Martin Enrique Valbuenas property interests in certain marital properties (See Exhibit J)
Jennifer M Haverty Valbuena was not represented by legal counsel against her Judge husband Martin Enrique Valbuena
The parties did not file the required Domestic Relations Filing Information as required by s Financial Affidavit with the Paulding Clerk of Court as required by OCGA sect 9-11-133
The parties failed to file the following required documents with the Clerk of Court
1) Domestic Relations Financial Affidavits
2) All federal and state income tax returns gift tax returns and intangible and personal property tax returns filed by the party or on the partys behalffor the past three (3) years
3) IRS forms W -2 1099 and K -1 forms for the past year if the income tax return for that year has not been prepared Also if such income tax return has not been prepared a year-ending pay stub received from the partys employer should be provided
4)Pay stubs or other evidence ofearned income for the twelve (12) months prior to the filing of the action
5)A statement by the producing party identifying the amount and source of all income received from all sources during the twelve (12) months preceding the filing of this action if same is not reflected on the pay stubs produced
6)Allloan applications and financial statements prepared or used within the three (3) years preceding the filing date of this action whether used for the purpose of obtaining or attempting to obtain credit for any other purpose
7) The most recent statement for any liquid fund assets including but not limited to profit-sharing 401-K money market stock and securities bonds accounts retirement and pension plan
8) Corporate partnership and trust tax returns for the last three (3) years if the producing party has an interest in a corporation partnership or trust greater than or equal to thirty (30) percent
9) Any Court Orders directing a party to payor receive spousal or child support even ifreceived from a third party
The parties were warned that Any Materially False Statement Knowingly Made in These Documents with the Intent to Defraud or Mislead Shall Subject Me to the Penalty for Perjury and May Be Considered a Fraud upon the Court
In the Paulding Superior Court the Valbuenas were not required to file the required financial information every other litigant must file in a domestic relations case
The parties are not obligated to pay child support to one another
Martin Enrique Valbuena was granted primary physical and joint legal custody ofthe minor children of the parties with the wife having secondary physical custody and joint legal custody
Jennifer M Haverty Valbuena filed the Petition for Separate Maintenance on March 8 2012
The Clerk ofPaulding County Superior Court filed the Petitioner and Summons on March 8 2012
Martin Valbuena acknowledged personal service of Jennifer Valbuenas Petition for Separate Maintenance on March 52012 three days before it was filed with the Clerk ofCourt and assigned a civil file action number
Judge Vinson executed the Decree ofSeparate Maintenance on March 12 20 I 0 coinciding with the delivery date ofyour former Defendants Intent to Sue letter sent to Martin Enrique Valbuena
As late as March 30 2012 at 529 pm Jennifer M Haverty Valbuena maintained on her facebook page that I am married to an incredible man (See Exhibit F)
On April 12012 Jennifer M Haverty Valbuena posted a photograph on her facebook page of a smiling Jennifer and Martin Enrique Valbuena together at the Atlanta restaurant N ava (See Exhibit G)
Not only was this Separate Maintenance action rushed through the Paulding Court system it appears the bona fide state of separation is a sham
By entering the Order for Separate Maintenance Judge Vinson did violate JQC Opinion 220
OPINION NO 220 Docket No 97-78 states as follows A sitting Superior Court Judge in a multi-judge circuit while expressly denying any bias prejudice or unfairness nevertheless requests an opinion on the following question Should a judge in a particular circuit ever preside or sit in judgment in the divorce ofanother judge from the same circuit or any matter relating to it contested or uncontested The response cites Canons 1 2 amp 3 ofthe Code ofJudicial Conduct cites case law of King v State 246 Ga 386 (1980) Wallace v Wallace 352 So2d 136(1977) and Commonwealth v Armor 398 A2d 173(1978) and ends with the following paragraph Simply stated the public must believe in the absolute integrity and impartiality of its judges and it is the obligation of this Commission to support and encourage such belief Consequently even without a showing ofactual bias prejudice or unfairness and regardless ofthe merits or timeliness ofa Motion to Recuse this Commission concludes that it is inappropriate for any trial court judge to preside in any action wherein one ofthe parties holds a judicial office on the same or any other court which sits in the same circuit
Voluntary Dismissal Without Prejudice
Your fonner Defendant cannot receive a fair hearing before any ofthe sitting or senior judges ofthe Paulding Judicial Circuit Judge James Osborne has presided over the entire above-captioned and vacated case Judge Osborne refuses to recuse himself Judge Osborne has taken my children from my custody without jurisdiction Martin Enrique Valbuenahad me jailed ChiefJudge Beavers has granted favors to Martin Enrique Valbuena Judge Vinson granted a Separate Maintenance Order taking custody rights from Ms Valbuena knowing she had disparate legal knowledge compared to her husband Chief Magistrate Probate Judge Pro Tern and Pro tern Superior Court Judge Martin Enrique Valbuena Jennifer Valbuenas Facebook postings after the Separate Maintenance Order raise questions to the sincerity ofthe property division between the parties Mr Valbuena is too ingrained a part of and politically connected and in the Paulding Judicial system for your fonner Defendant to prevail on the merits ofher claims and your fonner Defendant wishes to end this Paulding County horne-cooking and assert her tort claims in an appropriate venue and forum
As such your Plaintiff respectfully voluntarily dismisses without prejudice her claim for Sanctions Against Martin Enrique Valbuena and foregoes the hearing directed by the Court of Appeals ofGeorgia in Lowe v Lowe Your fonner Defendant will assert her claims against Martin Enrique Valbuena and Judge James Osborne in a more appropriate and fair forum This sanctions hearing and the resulting monetary sanctions cannot begin to compensate your fonner Defendant for the damages caused by the above-described tort-feasors
ProSe 279 Crossroads Estates Road Newnan GA 30265 (404) 704-7058
EXHIBIT A
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER APPOINTING MAGISTRATE JUDGE TO HANDIJR
EMERGENCY MATIERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to eX parte family violence petitions This appoinunent is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
July 26 2010 through and including July 302010
SO ORDERED this 16mday ofJuly 2010
Marrin Enrique Valbuena Judge 0 t
Magistrate Court of Paulding County -laquo) c CI rr=10
Sr~ ~ l== C= roo) GI_shy11()7ns N (jZi Or z 0 c~x
J~ drmiddot lP(Ofded in Milute Book~ c II lt0
~ page~ Pauldillg C~nlyGeoqpa T g ( (
bull 1- 0 ell nns1llbday 01 i ~ mI Z CI
~ reva W Shelton Clerl4 of SupertorCaurt ~
EXHIBIT B
STATE OF GEORGIA
ORDER APPOINTIlG MAGISTRATE JlDGE TO IIA~DLE
EMERGENCY MATTERS I~ SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after dtlc diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is bereby appointed to act in such emergency matters which may
include but are not limited to ex pane family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCOA Scction 15-1-91 and is effective
January 192010 through and including January 222010
SO ORDERED this 13th day ofJanuary 2010
CONSENTED TO
~cbb Martin Enrique Valbuena Judge Magistrate Court ofPaulding County
EXHIBT C
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER AfPOINTlNG MAGISTRATE JUDGE TO HANDLE
EMERGENCY MATTERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to ex parte family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
January 21 2009 through and including January 232009
SO ORDERED this IlJjday ofJanuary 2009
CONSENTED TO _- Q
~~ IQS 0 c
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WJIuntarIty IUbmI myself the jUrtIdIctfon ofdie SUperfor Court of Pautdng COUnty
IIId any I may hive to such venue
INa_ 2012
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before me an 0IIIar duly UtIorized to
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Page 1 of3
EXHIBIT Jurtf--shy o 0
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STATlOP _ J ) ) CIVILAC11ION PILI
v J 1llUl1IOI)Qtv G3~_Kv I )
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Upon coullldenltlDn ttl this ase upon ewfdencIe SIUbmIIttd bull provtded Or law
It aMjudgment tithe Court tIIIIt bull Decree ttl SIperIte MelntelNIIICe be
the
The Court custoctv tithe ChIIdrIft or the PartIes In ~WIIh the
IWtiIsSIUIeIliIIlt ~ wtIIch tied wIh the Court In deterrrIing chtIt
supfICIrt the Court IndII$ fcIIIov$
ChId suppaet In this mIbr Is dItennfned for two (2) chlldNn and the
CIlIIlSupport~ludl_hereIoiAIU8ldInceWlthOcGA 119-5-12
The NotMrI Gra1ncome Is $250000I1nOIth end the FMher1 Monthly
Gl-1ncoIM Is tl0OOO00m0nth The Parents CombINd AdjUllild Income is
$1uoooo he BIlle ChId Support 0blgIti0n (8CS011ur ttIe C1IIldren is
$2o35ao The MoIIers pro ortne acso 2000 WhIch equalS
$40700m0ntb end the pro -shere ttl tNt mount 1180 WhIch
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Page 2 of3
o o IIlIIddIIOn the FIltW is enIIted to IIiIIjuItmtItts for the chIIds heIIth
InIurIncIt MIl wort dIId Taking these adjuritment$lntO
JiCCOUIt the PrIiIIumptIyene ChIld Suppart AmrMIt $4eOlO fer the MGdIer and
$157480 fDrthe Hawevtr ttIt MottIer IS entkIId to addItIOnII nonshy
spedk ctevIItIon Ihe IlIOIIIG to bit exefCIIInt adcIItIonII QItlOdtat time
wII the QIIchn bullbull -it~ the PIrtIeS ]OInt phyIIaII cuMocIy 1MrusonI for
tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
induded In the PIretItI 0I1id SUpport wartcsheet TIIdng dIIs IddItfonII
cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
The FIIlherIs ordered to prwMde medIcII dentII ~ IIaideAt anct
- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
(18) old -COtMI iIICOIId
The Court IIIIISIIIImonr II tbIIows none
The SeallmettetIIIIed IIICo IIetwIen the dabId the 13
- u1S _01Y 20121amp fncorpOId III ~ and MIdI bull
bull - 80th PIIIndIrand DetelMIMt ordInId anIt commended to SUIclIy
GIfIPIr WIttI -1iWIIY pnMIIan 01 the DecretI 01 StpInte ~
DECReE eneAED this ~ rII MInh 2012
JuGge G V PIuIdI County SupIrtar Court I8uIdIng ludIdII CIItuIt ~
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EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
However the basis for the motion was a matter ofwhich Judge Osborne has personal knowledge to wit That Martin Enrique Valbuena is a judicial peer as Pro Tern Superior Court Judge Chief Magistrate of Paulding County and Pro Tern Probate Judge of Paulding County
Judge Osborne has judicial notice knows and has actual knowledge that Martin Enrique Valbuena has been appointed as a Pro Tern Superior Court Judge to act in such emergency matters which may include but are not limited to ex parte family violence petitioner when violence petitions when the other five (5) regular or senior judges are unavailable (See Chief Judge Beavers appointment of Martin Enrique Valbuena to Superior Court Judge marked as Exhibits 12 amp 3)
Judicial Canon 3(E)(1) provides that judges shall disqualify in any proceeding in which their impartiality might reasonably be questioned
Judge James Osborne is a witness to the fraudulent and untrue statements made at the ex parte custody hearing by Valbuena and the Plaintiff
Judge Osborne failed to have recorded or transcribed or mark evidence that he considered in this one-sided hearing that gives rise to your former Defendants claim for tortious interference with child custody against both Valbuena and Judge Osborne
Moreover when a judge testifies as a witness a lawyer who regularly appears before the judge may be placed in the awkward position ofcross-examining the judge Ajudge may however testify when properly summoned Commentary to Judicial Canon 2B ofthe Georgia Code ofJudicial Conduct
Despite knowing that he is a witness probable defendant and a judge that improvidently acted without jurisdiction he refuses to recuse himself in this matter ofSanctions Hearing Against Martin Enrique Valbuena See ChiefJudge William F Lee Jrs January 212004 Order vacating ex parte custody relief granted to the former Plaintiff Michael L Lowe and marked as Attachment C)
For whatever reason Judge Osborne will not release said Sanctions Hearing to the Coweta Superior Court the court of continuing and exclusive jurisdiction over this matter
Your former Defendant shows that she will not receive a fair and impartial hearing before Paulding Superior Court with Judge James Osborne presiding
Required Recusal of Other Paulding Superior Court Judges
Paulding Superior Court Chief Judge Tonney S Beavers
Your former Defendant has no faith that she will receive a fair tria1 by any of the Judges of the Paulding Judicial Circuit where Martin Enrique Valbuena is involved and concerned
Chief Judge Tonney S Beavers has appointed Martin Enrique Valbuena to the level of Paulding Superior Court Judge on several occasions (Exhibits A Band C )
Chief Judge Tonney SBeavers was given notice ofthe Motion to Recuse via first class mail and the Motion to Recuse specifically requested that he intervene and assign a disinterested non-Paulding County Superior Court Judge to conduct this sanctions hearing (See Exhibit K)
The Court ofAppeals noted the special favors ChiefJudge Tonney S Beavers bestows upon judicial peer Martin Enrique Valbuena in Union Maintenance Inc v Wilson 595 SE 2d 376 (2004)
The Court ofAppeals noted that ChiefJudge Beavers conducted a trial and Mr Valhuenas client lost and on January 292003 ChiefJudge Beavers entered judgment against him in the amount of $2521819 Chief Judge Beavers signed the hand-written the $2521819 judgment and found Mr Valbuenas clients Answer to be Untrue (See Exhihit E) Thereafter the Answer in the case was taken from the case file and all evidence of its entry with the Clerk of Clerk had been erased Subsequently Martin Enrique Valbuena presented a default judgment to Chief Judge Beavers in an ex parte hearing reducing the judgment to $50 The opposing attorney who had no notice ofthe hearing or received call from the Court requesting his presence took great pains to find a Paulding Clerk red-stamp copy ofthe missing Answer ChiefJudge Beavers certified the found red stamp Answer as authentic but refused to vacate Valbuena s fraudulently obtained default judgment The case was appealed and the Court of Appeals of Georgia overturned Chief Judge Beavers found against Martin Valbuena and his client and reinstated the $2521819 judgment Thereafter Wilson then filed bankruptcy erasing the long fought debt
ChiefJudge Beavers had no legal authority to change his judgment rendered at trial and reduce the judgment amount from $2521819 to a default judgment of $50
Without authority orjurisdiction ChiefJudge Tonny S Beavers reduced the trial judgment whether by fraud or favor for Martin Enrique Valbuena on behalf of his previously impeached and untruthful client Charles Wilson (See Attachment E)
Paulding Superior Court Judge Kenneth G Vinson
On March 9 2012 the Court ofAppeals ofGeorgia found in favor ofElisa M Lowe and found that Paulding County had no jurisdiction whatsoever in the Lowes custody matters
The holding directed monetary sanctions to be considered against Martin Enrique Valbuena for his misdeeds in the Paulding and Coweta Superior Courts
The Lowe v Lowe holding also allowed your former Defendant to pursue and assert a host ofother torts against Valbuena including but not limited to false arrest false imprisonment tortious interference with custody abuse ofprocess and malicious prosecution
On March 8 2012 in an effort to shield personal property and assets from judgment and attachment Martin Enrique Valbuena and his wife Jennifer M Haverty Valbuena did file a Separate Maintenance Action in the Paulding Superior Court12-CV-926-KV
Reminiscent of the Judge OsborneGlen Richards sealed divorce proceedings Judge Vinson was presented with the Separate Maintenance Petition
Four days after the initial filing of the Petition Judge Vinson did execute and issue an Decree for Separate Maintenance giving Jennifer M Haverty Valbuena certain rights of marital property and extinguishing Martin Enrique Valbuenas property interests in certain marital properties (See Exhibit J)
Jennifer M Haverty Valbuena was not represented by legal counsel against her Judge husband Martin Enrique Valbuena
The parties did not file the required Domestic Relations Filing Information as required by s Financial Affidavit with the Paulding Clerk of Court as required by OCGA sect 9-11-133
The parties failed to file the following required documents with the Clerk of Court
1) Domestic Relations Financial Affidavits
2) All federal and state income tax returns gift tax returns and intangible and personal property tax returns filed by the party or on the partys behalffor the past three (3) years
3) IRS forms W -2 1099 and K -1 forms for the past year if the income tax return for that year has not been prepared Also if such income tax return has not been prepared a year-ending pay stub received from the partys employer should be provided
4)Pay stubs or other evidence ofearned income for the twelve (12) months prior to the filing of the action
5)A statement by the producing party identifying the amount and source of all income received from all sources during the twelve (12) months preceding the filing of this action if same is not reflected on the pay stubs produced
6)Allloan applications and financial statements prepared or used within the three (3) years preceding the filing date of this action whether used for the purpose of obtaining or attempting to obtain credit for any other purpose
7) The most recent statement for any liquid fund assets including but not limited to profit-sharing 401-K money market stock and securities bonds accounts retirement and pension plan
8) Corporate partnership and trust tax returns for the last three (3) years if the producing party has an interest in a corporation partnership or trust greater than or equal to thirty (30) percent
9) Any Court Orders directing a party to payor receive spousal or child support even ifreceived from a third party
The parties were warned that Any Materially False Statement Knowingly Made in These Documents with the Intent to Defraud or Mislead Shall Subject Me to the Penalty for Perjury and May Be Considered a Fraud upon the Court
In the Paulding Superior Court the Valbuenas were not required to file the required financial information every other litigant must file in a domestic relations case
The parties are not obligated to pay child support to one another
Martin Enrique Valbuena was granted primary physical and joint legal custody ofthe minor children of the parties with the wife having secondary physical custody and joint legal custody
Jennifer M Haverty Valbuena filed the Petition for Separate Maintenance on March 8 2012
The Clerk ofPaulding County Superior Court filed the Petitioner and Summons on March 8 2012
Martin Valbuena acknowledged personal service of Jennifer Valbuenas Petition for Separate Maintenance on March 52012 three days before it was filed with the Clerk ofCourt and assigned a civil file action number
Judge Vinson executed the Decree ofSeparate Maintenance on March 12 20 I 0 coinciding with the delivery date ofyour former Defendants Intent to Sue letter sent to Martin Enrique Valbuena
As late as March 30 2012 at 529 pm Jennifer M Haverty Valbuena maintained on her facebook page that I am married to an incredible man (See Exhibit F)
On April 12012 Jennifer M Haverty Valbuena posted a photograph on her facebook page of a smiling Jennifer and Martin Enrique Valbuena together at the Atlanta restaurant N ava (See Exhibit G)
Not only was this Separate Maintenance action rushed through the Paulding Court system it appears the bona fide state of separation is a sham
By entering the Order for Separate Maintenance Judge Vinson did violate JQC Opinion 220
OPINION NO 220 Docket No 97-78 states as follows A sitting Superior Court Judge in a multi-judge circuit while expressly denying any bias prejudice or unfairness nevertheless requests an opinion on the following question Should a judge in a particular circuit ever preside or sit in judgment in the divorce ofanother judge from the same circuit or any matter relating to it contested or uncontested The response cites Canons 1 2 amp 3 ofthe Code ofJudicial Conduct cites case law of King v State 246 Ga 386 (1980) Wallace v Wallace 352 So2d 136(1977) and Commonwealth v Armor 398 A2d 173(1978) and ends with the following paragraph Simply stated the public must believe in the absolute integrity and impartiality of its judges and it is the obligation of this Commission to support and encourage such belief Consequently even without a showing ofactual bias prejudice or unfairness and regardless ofthe merits or timeliness ofa Motion to Recuse this Commission concludes that it is inappropriate for any trial court judge to preside in any action wherein one ofthe parties holds a judicial office on the same or any other court which sits in the same circuit
Voluntary Dismissal Without Prejudice
Your fonner Defendant cannot receive a fair hearing before any ofthe sitting or senior judges ofthe Paulding Judicial Circuit Judge James Osborne has presided over the entire above-captioned and vacated case Judge Osborne refuses to recuse himself Judge Osborne has taken my children from my custody without jurisdiction Martin Enrique Valbuenahad me jailed ChiefJudge Beavers has granted favors to Martin Enrique Valbuena Judge Vinson granted a Separate Maintenance Order taking custody rights from Ms Valbuena knowing she had disparate legal knowledge compared to her husband Chief Magistrate Probate Judge Pro Tern and Pro tern Superior Court Judge Martin Enrique Valbuena Jennifer Valbuenas Facebook postings after the Separate Maintenance Order raise questions to the sincerity ofthe property division between the parties Mr Valbuena is too ingrained a part of and politically connected and in the Paulding Judicial system for your fonner Defendant to prevail on the merits ofher claims and your fonner Defendant wishes to end this Paulding County horne-cooking and assert her tort claims in an appropriate venue and forum
As such your Plaintiff respectfully voluntarily dismisses without prejudice her claim for Sanctions Against Martin Enrique Valbuena and foregoes the hearing directed by the Court of Appeals ofGeorgia in Lowe v Lowe Your fonner Defendant will assert her claims against Martin Enrique Valbuena and Judge James Osborne in a more appropriate and fair forum This sanctions hearing and the resulting monetary sanctions cannot begin to compensate your fonner Defendant for the damages caused by the above-described tort-feasors
ProSe 279 Crossroads Estates Road Newnan GA 30265 (404) 704-7058
EXHIBIT A
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER APPOINTING MAGISTRATE JUDGE TO HANDIJR
EMERGENCY MATIERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to eX parte family violence petitions This appoinunent is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
July 26 2010 through and including July 302010
SO ORDERED this 16mday ofJuly 2010
Marrin Enrique Valbuena Judge 0 t
Magistrate Court of Paulding County -laquo) c CI rr=10
Sr~ ~ l== C= roo) GI_shy11()7ns N (jZi Or z 0 c~x
J~ drmiddot lP(Ofded in Milute Book~ c II lt0
~ page~ Pauldillg C~nlyGeoqpa T g ( (
bull 1- 0 ell nns1llbday 01 i ~ mI Z CI
~ reva W Shelton Clerl4 of SupertorCaurt ~
EXHIBIT B
STATE OF GEORGIA
ORDER APPOINTIlG MAGISTRATE JlDGE TO IIA~DLE
EMERGENCY MATTERS I~ SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after dtlc diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is bereby appointed to act in such emergency matters which may
include but are not limited to ex pane family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCOA Scction 15-1-91 and is effective
January 192010 through and including January 222010
SO ORDERED this 13th day ofJanuary 2010
CONSENTED TO
~cbb Martin Enrique Valbuena Judge Magistrate Court ofPaulding County
EXHIBT C
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER AfPOINTlNG MAGISTRATE JUDGE TO HANDLE
EMERGENCY MATTERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to ex parte family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
January 21 2009 through and including January 232009
SO ORDERED this IlJjday ofJanuary 2009
CONSENTED TO _- Q
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lMartin Enrique Valbuena udge ~ Z
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WJIuntarIty IUbmI myself the jUrtIdIctfon ofdie SUperfor Court of Pautdng COUnty
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STATE OF GEORGIAl (X)UNTY OF MUlDI
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IdmInIStler 0MhS In
being duIV sworn
__ilia In the
before me an 0IIIar duly UtIorized to
StIle of GeorgIa JennIfer M VIIbuena who abr
that the fads contained In her PetIIon for S4IIperate
IaWSampft are true and cortecent to the best Of
ITAft OP GEOMJA
her knowledge and
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EXHIBIT Jurtf--shy o 0
DI bullbullCOURfOPMUCOUIITY
STATlOP _ J ) ) CIVILAC11ION PILI
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bull bull D
Upon coullldenltlDn ttl this ase upon ewfdencIe SIUbmIIttd bull provtded Or law
It aMjudgment tithe Court tIIIIt bull Decree ttl SIperIte MelntelNIIICe be
the
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supfICIrt the Court IndII$ fcIIIov$
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CIlIIlSupport~ludl_hereIoiAIU8ldInceWlthOcGA 119-5-12
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$1uoooo he BIlle ChId Support 0blgIti0n (8CS011ur ttIe C1IIldren is
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tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
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cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
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- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
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EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
Chief Judge Tonney SBeavers was given notice ofthe Motion to Recuse via first class mail and the Motion to Recuse specifically requested that he intervene and assign a disinterested non-Paulding County Superior Court Judge to conduct this sanctions hearing (See Exhibit K)
The Court ofAppeals noted the special favors ChiefJudge Tonney S Beavers bestows upon judicial peer Martin Enrique Valbuena in Union Maintenance Inc v Wilson 595 SE 2d 376 (2004)
The Court ofAppeals noted that ChiefJudge Beavers conducted a trial and Mr Valhuenas client lost and on January 292003 ChiefJudge Beavers entered judgment against him in the amount of $2521819 Chief Judge Beavers signed the hand-written the $2521819 judgment and found Mr Valbuenas clients Answer to be Untrue (See Exhihit E) Thereafter the Answer in the case was taken from the case file and all evidence of its entry with the Clerk of Clerk had been erased Subsequently Martin Enrique Valbuena presented a default judgment to Chief Judge Beavers in an ex parte hearing reducing the judgment to $50 The opposing attorney who had no notice ofthe hearing or received call from the Court requesting his presence took great pains to find a Paulding Clerk red-stamp copy ofthe missing Answer ChiefJudge Beavers certified the found red stamp Answer as authentic but refused to vacate Valbuena s fraudulently obtained default judgment The case was appealed and the Court of Appeals of Georgia overturned Chief Judge Beavers found against Martin Valbuena and his client and reinstated the $2521819 judgment Thereafter Wilson then filed bankruptcy erasing the long fought debt
ChiefJudge Beavers had no legal authority to change his judgment rendered at trial and reduce the judgment amount from $2521819 to a default judgment of $50
Without authority orjurisdiction ChiefJudge Tonny S Beavers reduced the trial judgment whether by fraud or favor for Martin Enrique Valbuena on behalf of his previously impeached and untruthful client Charles Wilson (See Attachment E)
Paulding Superior Court Judge Kenneth G Vinson
On March 9 2012 the Court ofAppeals ofGeorgia found in favor ofElisa M Lowe and found that Paulding County had no jurisdiction whatsoever in the Lowes custody matters
The holding directed monetary sanctions to be considered against Martin Enrique Valbuena for his misdeeds in the Paulding and Coweta Superior Courts
The Lowe v Lowe holding also allowed your former Defendant to pursue and assert a host ofother torts against Valbuena including but not limited to false arrest false imprisonment tortious interference with custody abuse ofprocess and malicious prosecution
On March 8 2012 in an effort to shield personal property and assets from judgment and attachment Martin Enrique Valbuena and his wife Jennifer M Haverty Valbuena did file a Separate Maintenance Action in the Paulding Superior Court12-CV-926-KV
Reminiscent of the Judge OsborneGlen Richards sealed divorce proceedings Judge Vinson was presented with the Separate Maintenance Petition
Four days after the initial filing of the Petition Judge Vinson did execute and issue an Decree for Separate Maintenance giving Jennifer M Haverty Valbuena certain rights of marital property and extinguishing Martin Enrique Valbuenas property interests in certain marital properties (See Exhibit J)
Jennifer M Haverty Valbuena was not represented by legal counsel against her Judge husband Martin Enrique Valbuena
The parties did not file the required Domestic Relations Filing Information as required by s Financial Affidavit with the Paulding Clerk of Court as required by OCGA sect 9-11-133
The parties failed to file the following required documents with the Clerk of Court
1) Domestic Relations Financial Affidavits
2) All federal and state income tax returns gift tax returns and intangible and personal property tax returns filed by the party or on the partys behalffor the past three (3) years
3) IRS forms W -2 1099 and K -1 forms for the past year if the income tax return for that year has not been prepared Also if such income tax return has not been prepared a year-ending pay stub received from the partys employer should be provided
4)Pay stubs or other evidence ofearned income for the twelve (12) months prior to the filing of the action
5)A statement by the producing party identifying the amount and source of all income received from all sources during the twelve (12) months preceding the filing of this action if same is not reflected on the pay stubs produced
6)Allloan applications and financial statements prepared or used within the three (3) years preceding the filing date of this action whether used for the purpose of obtaining or attempting to obtain credit for any other purpose
7) The most recent statement for any liquid fund assets including but not limited to profit-sharing 401-K money market stock and securities bonds accounts retirement and pension plan
8) Corporate partnership and trust tax returns for the last three (3) years if the producing party has an interest in a corporation partnership or trust greater than or equal to thirty (30) percent
9) Any Court Orders directing a party to payor receive spousal or child support even ifreceived from a third party
The parties were warned that Any Materially False Statement Knowingly Made in These Documents with the Intent to Defraud or Mislead Shall Subject Me to the Penalty for Perjury and May Be Considered a Fraud upon the Court
In the Paulding Superior Court the Valbuenas were not required to file the required financial information every other litigant must file in a domestic relations case
The parties are not obligated to pay child support to one another
Martin Enrique Valbuena was granted primary physical and joint legal custody ofthe minor children of the parties with the wife having secondary physical custody and joint legal custody
Jennifer M Haverty Valbuena filed the Petition for Separate Maintenance on March 8 2012
The Clerk ofPaulding County Superior Court filed the Petitioner and Summons on March 8 2012
Martin Valbuena acknowledged personal service of Jennifer Valbuenas Petition for Separate Maintenance on March 52012 three days before it was filed with the Clerk ofCourt and assigned a civil file action number
Judge Vinson executed the Decree ofSeparate Maintenance on March 12 20 I 0 coinciding with the delivery date ofyour former Defendants Intent to Sue letter sent to Martin Enrique Valbuena
As late as March 30 2012 at 529 pm Jennifer M Haverty Valbuena maintained on her facebook page that I am married to an incredible man (See Exhibit F)
On April 12012 Jennifer M Haverty Valbuena posted a photograph on her facebook page of a smiling Jennifer and Martin Enrique Valbuena together at the Atlanta restaurant N ava (See Exhibit G)
Not only was this Separate Maintenance action rushed through the Paulding Court system it appears the bona fide state of separation is a sham
By entering the Order for Separate Maintenance Judge Vinson did violate JQC Opinion 220
OPINION NO 220 Docket No 97-78 states as follows A sitting Superior Court Judge in a multi-judge circuit while expressly denying any bias prejudice or unfairness nevertheless requests an opinion on the following question Should a judge in a particular circuit ever preside or sit in judgment in the divorce ofanother judge from the same circuit or any matter relating to it contested or uncontested The response cites Canons 1 2 amp 3 ofthe Code ofJudicial Conduct cites case law of King v State 246 Ga 386 (1980) Wallace v Wallace 352 So2d 136(1977) and Commonwealth v Armor 398 A2d 173(1978) and ends with the following paragraph Simply stated the public must believe in the absolute integrity and impartiality of its judges and it is the obligation of this Commission to support and encourage such belief Consequently even without a showing ofactual bias prejudice or unfairness and regardless ofthe merits or timeliness ofa Motion to Recuse this Commission concludes that it is inappropriate for any trial court judge to preside in any action wherein one ofthe parties holds a judicial office on the same or any other court which sits in the same circuit
Voluntary Dismissal Without Prejudice
Your fonner Defendant cannot receive a fair hearing before any ofthe sitting or senior judges ofthe Paulding Judicial Circuit Judge James Osborne has presided over the entire above-captioned and vacated case Judge Osborne refuses to recuse himself Judge Osborne has taken my children from my custody without jurisdiction Martin Enrique Valbuenahad me jailed ChiefJudge Beavers has granted favors to Martin Enrique Valbuena Judge Vinson granted a Separate Maintenance Order taking custody rights from Ms Valbuena knowing she had disparate legal knowledge compared to her husband Chief Magistrate Probate Judge Pro Tern and Pro tern Superior Court Judge Martin Enrique Valbuena Jennifer Valbuenas Facebook postings after the Separate Maintenance Order raise questions to the sincerity ofthe property division between the parties Mr Valbuena is too ingrained a part of and politically connected and in the Paulding Judicial system for your fonner Defendant to prevail on the merits ofher claims and your fonner Defendant wishes to end this Paulding County horne-cooking and assert her tort claims in an appropriate venue and forum
As such your Plaintiff respectfully voluntarily dismisses without prejudice her claim for Sanctions Against Martin Enrique Valbuena and foregoes the hearing directed by the Court of Appeals ofGeorgia in Lowe v Lowe Your fonner Defendant will assert her claims against Martin Enrique Valbuena and Judge James Osborne in a more appropriate and fair forum This sanctions hearing and the resulting monetary sanctions cannot begin to compensate your fonner Defendant for the damages caused by the above-described tort-feasors
ProSe 279 Crossroads Estates Road Newnan GA 30265 (404) 704-7058
EXHIBIT A
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER APPOINTING MAGISTRATE JUDGE TO HANDIJR
EMERGENCY MATIERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to eX parte family violence petitions This appoinunent is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
July 26 2010 through and including July 302010
SO ORDERED this 16mday ofJuly 2010
Marrin Enrique Valbuena Judge 0 t
Magistrate Court of Paulding County -laquo) c CI rr=10
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EXHIBIT B
STATE OF GEORGIA
ORDER APPOINTIlG MAGISTRATE JlDGE TO IIA~DLE
EMERGENCY MATTERS I~ SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after dtlc diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is bereby appointed to act in such emergency matters which may
include but are not limited to ex pane family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCOA Scction 15-1-91 and is effective
January 192010 through and including January 222010
SO ORDERED this 13th day ofJanuary 2010
CONSENTED TO
~cbb Martin Enrique Valbuena Judge Magistrate Court ofPaulding County
EXHIBT C
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER AfPOINTlNG MAGISTRATE JUDGE TO HANDLE
EMERGENCY MATTERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to ex parte family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
January 21 2009 through and including January 232009
SO ORDERED this IlJjday ofJanuary 2009
CONSENTED TO _- Q
~~ IQS 0 c
lMartin Enrique Valbuena udge ~ Z
2Magistrate Court of Paulding County C 0 71 -gtlt Do ~ - sect _ ~
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EXHIBIT H
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WJIuntarIty IUbmI myself the jUrtIdIctfon ofdie SUperfor Court of Pautdng COUnty
IIId any I may hive to such venue
INa_ 2012
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STATE OF GEORGIAl (X)UNTY OF MUlDI
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IdmInIStler 0MhS In
being duIV sworn
__ilia In the
before me an 0IIIar duly UtIorized to
StIle of GeorgIa JennIfer M VIIbuena who abr
that the fads contained In her PetIIon for S4IIperate
IaWSampft are true and cortecent to the best Of
ITAft OP GEOMJA
her knowledge and
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-----
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EXHIBIT Jurtf--shy o 0
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STATlOP _ J ) ) CIVILAC11ION PILI
v J 1llUl1IOI)Qtv G3~_Kv I )
bull bull D
Upon coullldenltlDn ttl this ase upon ewfdencIe SIUbmIIttd bull provtded Or law
It aMjudgment tithe Court tIIIIt bull Decree ttl SIperIte MelntelNIIICe be
the
The Court custoctv tithe ChIIdrIft or the PartIes In ~WIIh the
IWtiIsSIUIeIliIIlt ~ wtIIch tied wIh the Court In deterrrIing chtIt
supfICIrt the Court IndII$ fcIIIov$
ChId suppaet In this mIbr Is dItennfned for two (2) chlldNn and the
CIlIIlSupport~ludl_hereIoiAIU8ldInceWlthOcGA 119-5-12
The NotMrI Gra1ncome Is $250000I1nOIth end the FMher1 Monthly
Gl-1ncoIM Is tl0OOO00m0nth The Parents CombINd AdjUllild Income is
$1uoooo he BIlle ChId Support 0blgIti0n (8CS011ur ttIe C1IIldren is
$2o35ao The MoIIers pro ortne acso 2000 WhIch equalS
$40700m0ntb end the pro -shere ttl tNt mount 1180 WhIch
$ll28OOnIOnth
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InIurIncIt MIl wort dIId Taking these adjuritment$lntO
JiCCOUIt the PrIiIIumptIyene ChIld Suppart AmrMIt $4eOlO fer the MGdIer and
$157480 fDrthe Hawevtr ttIt MottIer IS entkIId to addItIOnII nonshy
spedk ctevIItIon Ihe IlIOIIIG to bit exefCIIInt adcIItIonII QItlOdtat time
wII the QIIchn bullbull -it~ the PIrtIeS ]OInt phyIIaII cuMocIy 1MrusonI for
tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
induded In the PIretItI 0I1id SUpport wartcsheet TIIdng dIIs IddItfonII
cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
The FIIlherIs ordered to prwMde medIcII dentII ~ IIaideAt anct
- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
(18) old -COtMI iIICOIId
The Court IIIIISIIIImonr II tbIIows none
The SeallmettetIIIIed IIICo IIetwIen the dabId the 13
- u1S _01Y 20121amp fncorpOId III ~ and MIdI bull
bull - 80th PIIIndIrand DetelMIMt ordInId anIt commended to SUIclIy
GIfIPIr WIttI -1iWIIY pnMIIan 01 the DecretI 01 StpInte ~
DECReE eneAED this ~ rII MInh 2012
JuGge G V PIuIdI County SupIrtar Court I8uIdIng ludIdII CIItuIt ~
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- ~-~~----~- --_~---
----~----~--~-~---------~- ~----
EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
Reminiscent of the Judge OsborneGlen Richards sealed divorce proceedings Judge Vinson was presented with the Separate Maintenance Petition
Four days after the initial filing of the Petition Judge Vinson did execute and issue an Decree for Separate Maintenance giving Jennifer M Haverty Valbuena certain rights of marital property and extinguishing Martin Enrique Valbuenas property interests in certain marital properties (See Exhibit J)
Jennifer M Haverty Valbuena was not represented by legal counsel against her Judge husband Martin Enrique Valbuena
The parties did not file the required Domestic Relations Filing Information as required by s Financial Affidavit with the Paulding Clerk of Court as required by OCGA sect 9-11-133
The parties failed to file the following required documents with the Clerk of Court
1) Domestic Relations Financial Affidavits
2) All federal and state income tax returns gift tax returns and intangible and personal property tax returns filed by the party or on the partys behalffor the past three (3) years
3) IRS forms W -2 1099 and K -1 forms for the past year if the income tax return for that year has not been prepared Also if such income tax return has not been prepared a year-ending pay stub received from the partys employer should be provided
4)Pay stubs or other evidence ofearned income for the twelve (12) months prior to the filing of the action
5)A statement by the producing party identifying the amount and source of all income received from all sources during the twelve (12) months preceding the filing of this action if same is not reflected on the pay stubs produced
6)Allloan applications and financial statements prepared or used within the three (3) years preceding the filing date of this action whether used for the purpose of obtaining or attempting to obtain credit for any other purpose
7) The most recent statement for any liquid fund assets including but not limited to profit-sharing 401-K money market stock and securities bonds accounts retirement and pension plan
8) Corporate partnership and trust tax returns for the last three (3) years if the producing party has an interest in a corporation partnership or trust greater than or equal to thirty (30) percent
9) Any Court Orders directing a party to payor receive spousal or child support even ifreceived from a third party
The parties were warned that Any Materially False Statement Knowingly Made in These Documents with the Intent to Defraud or Mislead Shall Subject Me to the Penalty for Perjury and May Be Considered a Fraud upon the Court
In the Paulding Superior Court the Valbuenas were not required to file the required financial information every other litigant must file in a domestic relations case
The parties are not obligated to pay child support to one another
Martin Enrique Valbuena was granted primary physical and joint legal custody ofthe minor children of the parties with the wife having secondary physical custody and joint legal custody
Jennifer M Haverty Valbuena filed the Petition for Separate Maintenance on March 8 2012
The Clerk ofPaulding County Superior Court filed the Petitioner and Summons on March 8 2012
Martin Valbuena acknowledged personal service of Jennifer Valbuenas Petition for Separate Maintenance on March 52012 three days before it was filed with the Clerk ofCourt and assigned a civil file action number
Judge Vinson executed the Decree ofSeparate Maintenance on March 12 20 I 0 coinciding with the delivery date ofyour former Defendants Intent to Sue letter sent to Martin Enrique Valbuena
As late as March 30 2012 at 529 pm Jennifer M Haverty Valbuena maintained on her facebook page that I am married to an incredible man (See Exhibit F)
On April 12012 Jennifer M Haverty Valbuena posted a photograph on her facebook page of a smiling Jennifer and Martin Enrique Valbuena together at the Atlanta restaurant N ava (See Exhibit G)
Not only was this Separate Maintenance action rushed through the Paulding Court system it appears the bona fide state of separation is a sham
By entering the Order for Separate Maintenance Judge Vinson did violate JQC Opinion 220
OPINION NO 220 Docket No 97-78 states as follows A sitting Superior Court Judge in a multi-judge circuit while expressly denying any bias prejudice or unfairness nevertheless requests an opinion on the following question Should a judge in a particular circuit ever preside or sit in judgment in the divorce ofanother judge from the same circuit or any matter relating to it contested or uncontested The response cites Canons 1 2 amp 3 ofthe Code ofJudicial Conduct cites case law of King v State 246 Ga 386 (1980) Wallace v Wallace 352 So2d 136(1977) and Commonwealth v Armor 398 A2d 173(1978) and ends with the following paragraph Simply stated the public must believe in the absolute integrity and impartiality of its judges and it is the obligation of this Commission to support and encourage such belief Consequently even without a showing ofactual bias prejudice or unfairness and regardless ofthe merits or timeliness ofa Motion to Recuse this Commission concludes that it is inappropriate for any trial court judge to preside in any action wherein one ofthe parties holds a judicial office on the same or any other court which sits in the same circuit
Voluntary Dismissal Without Prejudice
Your fonner Defendant cannot receive a fair hearing before any ofthe sitting or senior judges ofthe Paulding Judicial Circuit Judge James Osborne has presided over the entire above-captioned and vacated case Judge Osborne refuses to recuse himself Judge Osborne has taken my children from my custody without jurisdiction Martin Enrique Valbuenahad me jailed ChiefJudge Beavers has granted favors to Martin Enrique Valbuena Judge Vinson granted a Separate Maintenance Order taking custody rights from Ms Valbuena knowing she had disparate legal knowledge compared to her husband Chief Magistrate Probate Judge Pro Tern and Pro tern Superior Court Judge Martin Enrique Valbuena Jennifer Valbuenas Facebook postings after the Separate Maintenance Order raise questions to the sincerity ofthe property division between the parties Mr Valbuena is too ingrained a part of and politically connected and in the Paulding Judicial system for your fonner Defendant to prevail on the merits ofher claims and your fonner Defendant wishes to end this Paulding County horne-cooking and assert her tort claims in an appropriate venue and forum
As such your Plaintiff respectfully voluntarily dismisses without prejudice her claim for Sanctions Against Martin Enrique Valbuena and foregoes the hearing directed by the Court of Appeals ofGeorgia in Lowe v Lowe Your fonner Defendant will assert her claims against Martin Enrique Valbuena and Judge James Osborne in a more appropriate and fair forum This sanctions hearing and the resulting monetary sanctions cannot begin to compensate your fonner Defendant for the damages caused by the above-described tort-feasors
ProSe 279 Crossroads Estates Road Newnan GA 30265 (404) 704-7058
EXHIBIT A
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER APPOINTING MAGISTRATE JUDGE TO HANDIJR
EMERGENCY MATIERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to eX parte family violence petitions This appoinunent is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
July 26 2010 through and including July 302010
SO ORDERED this 16mday ofJuly 2010
Marrin Enrique Valbuena Judge 0 t
Magistrate Court of Paulding County -laquo) c CI rr=10
Sr~ ~ l== C= roo) GI_shy11()7ns N (jZi Or z 0 c~x
J~ drmiddot lP(Ofded in Milute Book~ c II lt0
~ page~ Pauldillg C~nlyGeoqpa T g ( (
bull 1- 0 ell nns1llbday 01 i ~ mI Z CI
~ reva W Shelton Clerl4 of SupertorCaurt ~
EXHIBIT B
STATE OF GEORGIA
ORDER APPOINTIlG MAGISTRATE JlDGE TO IIA~DLE
EMERGENCY MATTERS I~ SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after dtlc diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is bereby appointed to act in such emergency matters which may
include but are not limited to ex pane family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCOA Scction 15-1-91 and is effective
January 192010 through and including January 222010
SO ORDERED this 13th day ofJanuary 2010
CONSENTED TO
~cbb Martin Enrique Valbuena Judge Magistrate Court ofPaulding County
EXHIBT C
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER AfPOINTlNG MAGISTRATE JUDGE TO HANDLE
EMERGENCY MATTERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to ex parte family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
January 21 2009 through and including January 232009
SO ORDERED this IlJjday ofJanuary 2009
CONSENTED TO _- Q
~~ IQS 0 c
lMartin Enrique Valbuena udge ~ Z
2Magistrate Court of Paulding County C 0 71 -gtlt Do ~ - sect _ ~
-() wZ fV UI ~
Piled and recorded In MInute Bookll- ~~
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WJIuntarIty IUbmI myself the jUrtIdIctfon ofdie SUperfor Court of Pautdng COUnty
IIId any I may hive to such venue
INa_ 2012
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httpclebnetcomJWebCaseManagementlImageheaderMpxRECTYPE=CYilampid=63030 2192004
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STATE OF GEORGIAl (X)UNTY OF MUlDI
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IdmInIStler 0MhS In
being duIV sworn
__ilia In the
before me an 0IIIar duly UtIorized to
StIle of GeorgIa JennIfer M VIIbuena who abr
that the fads contained In her PetIIon for S4IIperate
IaWSampft are true and cortecent to the best Of
ITAft OP GEOMJA
her knowledge and
lIIIO 1M 1 cloy or - 2012
i~ Swom toJld subscr1bed beIore tbil ~ fI
httpcldaloetCQDIIVcbCaseManagementJImageheaderspxRECTYPE=ctilampid=63030 21912004
-----
Page 1 of3
EXHIBIT Jurtf--shy o 0
DI bullbullCOURfOPMUCOUIITY
STATlOP _ J ) ) CIVILAC11ION PILI
v J 1llUl1IOI)Qtv G3~_Kv I )
bull bull D
Upon coullldenltlDn ttl this ase upon ewfdencIe SIUbmIIttd bull provtded Or law
It aMjudgment tithe Court tIIIIt bull Decree ttl SIperIte MelntelNIIICe be
the
The Court custoctv tithe ChIIdrIft or the PartIes In ~WIIh the
IWtiIsSIUIeIliIIlt ~ wtIIch tied wIh the Court In deterrrIing chtIt
supfICIrt the Court IndII$ fcIIIov$
ChId suppaet In this mIbr Is dItennfned for two (2) chlldNn and the
CIlIIlSupport~ludl_hereIoiAIU8ldInceWlthOcGA 119-5-12
The NotMrI Gra1ncome Is $250000I1nOIth end the FMher1 Monthly
Gl-1ncoIM Is tl0OOO00m0nth The Parents CombINd AdjUllild Income is
$1uoooo he BIlle ChId Support 0blgIti0n (8CS011ur ttIe C1IIldren is
$2o35ao The MoIIers pro ortne acso 2000 WhIch equalS
$40700m0ntb end the pro -shere ttl tNt mount 1180 WhIch
$ll28OOnIOnth
bttpllcleJksnetCODIIWebCaseManagementImageheaderaspx1REClYPE=ctilampid~3181 2)12004
Page 2 of3
o o IIlIIddIIOn the FIltW is enIIted to IIiIIjuItmtItts for the chIIds heIIth
InIurIncIt MIl wort dIId Taking these adjuritment$lntO
JiCCOUIt the PrIiIIumptIyene ChIld Suppart AmrMIt $4eOlO fer the MGdIer and
$157480 fDrthe Hawevtr ttIt MottIer IS entkIId to addItIOnII nonshy
spedk ctevIItIon Ihe IlIOIIIG to bit exefCIIInt adcIItIonII QItlOdtat time
wII the QIIchn bullbull -it~ the PIrtIeS ]OInt phyIIaII cuMocIy 1MrusonI for
tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
induded In the PIretItI 0I1id SUpport wartcsheet TIIdng dIIs IddItfonII
cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
The FIIlherIs ordered to prwMde medIcII dentII ~ IIaideAt anct
- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
(18) old -COtMI iIICOIId
The Court IIIIISIIIImonr II tbIIows none
The SeallmettetIIIIed IIICo IIetwIen the dabId the 13
- u1S _01Y 20121amp fncorpOId III ~ and MIdI bull
bull - 80th PIIIndIrand DetelMIMt ordInId anIt commended to SUIclIy
GIfIPIr WIttI -1iWIIY pnMIIan 01 the DecretI 01 StpInte ~
DECReE eneAED this ~ rII MInh 2012
JuGge G V PIuIdI County SupIrtar Court I8uIdIng ludIdII CIItuIt ~
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- ~-~~----~- --_~---
----~----~--~-~---------~- ~----
EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
In the Paulding Superior Court the Valbuenas were not required to file the required financial information every other litigant must file in a domestic relations case
The parties are not obligated to pay child support to one another
Martin Enrique Valbuena was granted primary physical and joint legal custody ofthe minor children of the parties with the wife having secondary physical custody and joint legal custody
Jennifer M Haverty Valbuena filed the Petition for Separate Maintenance on March 8 2012
The Clerk ofPaulding County Superior Court filed the Petitioner and Summons on March 8 2012
Martin Valbuena acknowledged personal service of Jennifer Valbuenas Petition for Separate Maintenance on March 52012 three days before it was filed with the Clerk ofCourt and assigned a civil file action number
Judge Vinson executed the Decree ofSeparate Maintenance on March 12 20 I 0 coinciding with the delivery date ofyour former Defendants Intent to Sue letter sent to Martin Enrique Valbuena
As late as March 30 2012 at 529 pm Jennifer M Haverty Valbuena maintained on her facebook page that I am married to an incredible man (See Exhibit F)
On April 12012 Jennifer M Haverty Valbuena posted a photograph on her facebook page of a smiling Jennifer and Martin Enrique Valbuena together at the Atlanta restaurant N ava (See Exhibit G)
Not only was this Separate Maintenance action rushed through the Paulding Court system it appears the bona fide state of separation is a sham
By entering the Order for Separate Maintenance Judge Vinson did violate JQC Opinion 220
OPINION NO 220 Docket No 97-78 states as follows A sitting Superior Court Judge in a multi-judge circuit while expressly denying any bias prejudice or unfairness nevertheless requests an opinion on the following question Should a judge in a particular circuit ever preside or sit in judgment in the divorce ofanother judge from the same circuit or any matter relating to it contested or uncontested The response cites Canons 1 2 amp 3 ofthe Code ofJudicial Conduct cites case law of King v State 246 Ga 386 (1980) Wallace v Wallace 352 So2d 136(1977) and Commonwealth v Armor 398 A2d 173(1978) and ends with the following paragraph Simply stated the public must believe in the absolute integrity and impartiality of its judges and it is the obligation of this Commission to support and encourage such belief Consequently even without a showing ofactual bias prejudice or unfairness and regardless ofthe merits or timeliness ofa Motion to Recuse this Commission concludes that it is inappropriate for any trial court judge to preside in any action wherein one ofthe parties holds a judicial office on the same or any other court which sits in the same circuit
Voluntary Dismissal Without Prejudice
Your fonner Defendant cannot receive a fair hearing before any ofthe sitting or senior judges ofthe Paulding Judicial Circuit Judge James Osborne has presided over the entire above-captioned and vacated case Judge Osborne refuses to recuse himself Judge Osborne has taken my children from my custody without jurisdiction Martin Enrique Valbuenahad me jailed ChiefJudge Beavers has granted favors to Martin Enrique Valbuena Judge Vinson granted a Separate Maintenance Order taking custody rights from Ms Valbuena knowing she had disparate legal knowledge compared to her husband Chief Magistrate Probate Judge Pro Tern and Pro tern Superior Court Judge Martin Enrique Valbuena Jennifer Valbuenas Facebook postings after the Separate Maintenance Order raise questions to the sincerity ofthe property division between the parties Mr Valbuena is too ingrained a part of and politically connected and in the Paulding Judicial system for your fonner Defendant to prevail on the merits ofher claims and your fonner Defendant wishes to end this Paulding County horne-cooking and assert her tort claims in an appropriate venue and forum
As such your Plaintiff respectfully voluntarily dismisses without prejudice her claim for Sanctions Against Martin Enrique Valbuena and foregoes the hearing directed by the Court of Appeals ofGeorgia in Lowe v Lowe Your fonner Defendant will assert her claims against Martin Enrique Valbuena and Judge James Osborne in a more appropriate and fair forum This sanctions hearing and the resulting monetary sanctions cannot begin to compensate your fonner Defendant for the damages caused by the above-described tort-feasors
ProSe 279 Crossroads Estates Road Newnan GA 30265 (404) 704-7058
EXHIBIT A
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER APPOINTING MAGISTRATE JUDGE TO HANDIJR
EMERGENCY MATIERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to eX parte family violence petitions This appoinunent is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
July 26 2010 through and including July 302010
SO ORDERED this 16mday ofJuly 2010
Marrin Enrique Valbuena Judge 0 t
Magistrate Court of Paulding County -laquo) c CI rr=10
Sr~ ~ l== C= roo) GI_shy11()7ns N (jZi Or z 0 c~x
J~ drmiddot lP(Ofded in Milute Book~ c II lt0
~ page~ Pauldillg C~nlyGeoqpa T g ( (
bull 1- 0 ell nns1llbday 01 i ~ mI Z CI
~ reva W Shelton Clerl4 of SupertorCaurt ~
EXHIBIT B
STATE OF GEORGIA
ORDER APPOINTIlG MAGISTRATE JlDGE TO IIA~DLE
EMERGENCY MATTERS I~ SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after dtlc diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is bereby appointed to act in such emergency matters which may
include but are not limited to ex pane family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCOA Scction 15-1-91 and is effective
January 192010 through and including January 222010
SO ORDERED this 13th day ofJanuary 2010
CONSENTED TO
~cbb Martin Enrique Valbuena Judge Magistrate Court ofPaulding County
EXHIBT C
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER AfPOINTlNG MAGISTRATE JUDGE TO HANDLE
EMERGENCY MATTERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to ex parte family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
January 21 2009 through and including January 232009
SO ORDERED this IlJjday ofJanuary 2009
CONSENTED TO _- Q
~~ IQS 0 c
lMartin Enrique Valbuena udge ~ Z
2Magistrate Court of Paulding County C 0 71 -gtlt Do ~ - sect _ ~
-() wZ fV UI ~
Piled and recorded In MInute Bookll- ~~
~ Pau_CounlyOeoIJlaRecOldJ ~dayor ampul~ mtli Treyena w SheIIon Clerk ofSuperlorCclull
~
~
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EXHIBT E
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EXHIBIT H
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WJIuntarIty IUbmI myself the jUrtIdIctfon ofdie SUperfor Court of Pautdng COUnty
IIId any I may hive to such venue
INa_ 2012
gt ~JA
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Page 1 ofl
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STATE OF GEORGIAl (X)UNTY OF MUlDI
I ~
IdmInIStler 0MhS In
being duIV sworn
__ilia In the
before me an 0IIIar duly UtIorized to
StIle of GeorgIa JennIfer M VIIbuena who abr
that the fads contained In her PetIIon for S4IIperate
IaWSampft are true and cortecent to the best Of
ITAft OP GEOMJA
her knowledge and
lIIIO 1M 1 cloy or - 2012
i~ Swom toJld subscr1bed beIore tbil ~ fI
httpcldaloetCQDIIVcbCaseManagementJImageheaderspxRECTYPE=ctilampid=63030 21912004
-----
Page 1 of3
EXHIBIT Jurtf--shy o 0
DI bullbullCOURfOPMUCOUIITY
STATlOP _ J ) ) CIVILAC11ION PILI
v J 1llUl1IOI)Qtv G3~_Kv I )
bull bull D
Upon coullldenltlDn ttl this ase upon ewfdencIe SIUbmIIttd bull provtded Or law
It aMjudgment tithe Court tIIIIt bull Decree ttl SIperIte MelntelNIIICe be
the
The Court custoctv tithe ChIIdrIft or the PartIes In ~WIIh the
IWtiIsSIUIeIliIIlt ~ wtIIch tied wIh the Court In deterrrIing chtIt
supfICIrt the Court IndII$ fcIIIov$
ChId suppaet In this mIbr Is dItennfned for two (2) chlldNn and the
CIlIIlSupport~ludl_hereIoiAIU8ldInceWlthOcGA 119-5-12
The NotMrI Gra1ncome Is $250000I1nOIth end the FMher1 Monthly
Gl-1ncoIM Is tl0OOO00m0nth The Parents CombINd AdjUllild Income is
$1uoooo he BIlle ChId Support 0blgIti0n (8CS011ur ttIe C1IIldren is
$2o35ao The MoIIers pro ortne acso 2000 WhIch equalS
$40700m0ntb end the pro -shere ttl tNt mount 1180 WhIch
$ll28OOnIOnth
bttpllcleJksnetCODIIWebCaseManagementImageheaderaspx1REClYPE=ctilampid~3181 2)12004
Page 2 of3
o o IIlIIddIIOn the FIltW is enIIted to IIiIIjuItmtItts for the chIIds heIIth
InIurIncIt MIl wort dIId Taking these adjuritment$lntO
JiCCOUIt the PrIiIIumptIyene ChIld Suppart AmrMIt $4eOlO fer the MGdIer and
$157480 fDrthe Hawevtr ttIt MottIer IS entkIId to addItIOnII nonshy
spedk ctevIItIon Ihe IlIOIIIG to bit exefCIIInt adcIItIonII QItlOdtat time
wII the QIIchn bullbull -it~ the PIrtIeS ]OInt phyIIaII cuMocIy 1MrusonI for
tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
induded In the PIretItI 0I1id SUpport wartcsheet TIIdng dIIs IddItfonII
cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
The FIIlherIs ordered to prwMde medIcII dentII ~ IIaideAt anct
- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
(18) old -COtMI iIICOIId
The Court IIIIISIIIImonr II tbIIows none
The SeallmettetIIIIed IIICo IIetwIen the dabId the 13
- u1S _01Y 20121amp fncorpOId III ~ and MIdI bull
bull - 80th PIIIndIrand DetelMIMt ordInId anIt commended to SUIclIy
GIfIPIr WIttI -1iWIIY pnMIIan 01 the DecretI 01 StpInte ~
DECReE eneAED this ~ rII MInh 2012
JuGge G V PIuIdI County SupIrtar Court I8uIdIng ludIdII CIItuIt ~
bttpf1cletksnetcomJWebCaseManagementJJmagebeaderaspxRBCTYPpound=CYiIampid~3181 2I9f2004
- ~-~~----~- --_~---
----~----~--~-~---------~- ~----
EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
Voluntary Dismissal Without Prejudice
Your fonner Defendant cannot receive a fair hearing before any ofthe sitting or senior judges ofthe Paulding Judicial Circuit Judge James Osborne has presided over the entire above-captioned and vacated case Judge Osborne refuses to recuse himself Judge Osborne has taken my children from my custody without jurisdiction Martin Enrique Valbuenahad me jailed ChiefJudge Beavers has granted favors to Martin Enrique Valbuena Judge Vinson granted a Separate Maintenance Order taking custody rights from Ms Valbuena knowing she had disparate legal knowledge compared to her husband Chief Magistrate Probate Judge Pro Tern and Pro tern Superior Court Judge Martin Enrique Valbuena Jennifer Valbuenas Facebook postings after the Separate Maintenance Order raise questions to the sincerity ofthe property division between the parties Mr Valbuena is too ingrained a part of and politically connected and in the Paulding Judicial system for your fonner Defendant to prevail on the merits ofher claims and your fonner Defendant wishes to end this Paulding County horne-cooking and assert her tort claims in an appropriate venue and forum
As such your Plaintiff respectfully voluntarily dismisses without prejudice her claim for Sanctions Against Martin Enrique Valbuena and foregoes the hearing directed by the Court of Appeals ofGeorgia in Lowe v Lowe Your fonner Defendant will assert her claims against Martin Enrique Valbuena and Judge James Osborne in a more appropriate and fair forum This sanctions hearing and the resulting monetary sanctions cannot begin to compensate your fonner Defendant for the damages caused by the above-described tort-feasors
ProSe 279 Crossroads Estates Road Newnan GA 30265 (404) 704-7058
EXHIBIT A
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER APPOINTING MAGISTRATE JUDGE TO HANDIJR
EMERGENCY MATIERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to eX parte family violence petitions This appoinunent is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
July 26 2010 through and including July 302010
SO ORDERED this 16mday ofJuly 2010
Marrin Enrique Valbuena Judge 0 t
Magistrate Court of Paulding County -laquo) c CI rr=10
Sr~ ~ l== C= roo) GI_shy11()7ns N (jZi Or z 0 c~x
J~ drmiddot lP(Ofded in Milute Book~ c II lt0
~ page~ Pauldillg C~nlyGeoqpa T g ( (
bull 1- 0 ell nns1llbday 01 i ~ mI Z CI
~ reva W Shelton Clerl4 of SupertorCaurt ~
EXHIBIT B
STATE OF GEORGIA
ORDER APPOINTIlG MAGISTRATE JlDGE TO IIA~DLE
EMERGENCY MATTERS I~ SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after dtlc diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is bereby appointed to act in such emergency matters which may
include but are not limited to ex pane family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCOA Scction 15-1-91 and is effective
January 192010 through and including January 222010
SO ORDERED this 13th day ofJanuary 2010
CONSENTED TO
~cbb Martin Enrique Valbuena Judge Magistrate Court ofPaulding County
EXHIBT C
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER AfPOINTlNG MAGISTRATE JUDGE TO HANDLE
EMERGENCY MATTERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to ex parte family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
January 21 2009 through and including January 232009
SO ORDERED this IlJjday ofJanuary 2009
CONSENTED TO _- Q
~~ IQS 0 c
lMartin Enrique Valbuena udge ~ Z
2Magistrate Court of Paulding County C 0 71 -gtlt Do ~ - sect _ ~
-() wZ fV UI ~
Piled and recorded In MInute Bookll- ~~
~ Pau_CounlyOeoIJlaRecOldJ ~dayor ampul~ mtli Treyena w SheIIon Clerk ofSuperlorCclull
~
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EXHIBT E
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EXHIBIT H
w
I bull DIIIIIInt
) ) ) ) CMt -=noN fILl ) ) ) ) )
I
I f
I
I I
tManE~
~ IIMCe atPetltIohrIMls Petitian fer 5epInIte MImtInInce and adcIItIonII service of
_ summons In 1I1C8d GIIe Is IInby WItwed By so doing I
WJIuntarIty IUbmI myself the jUrtIdIctfon ofdie SUperfor Court of Pautdng COUnty
IIId any I may hive to such venue
INa_ 2012
gt ~JA
b I I
1IOtMfPU8UC=CCUflTY I i
oalnllnlall~ Itt
httpclebnetcomJWebCaseManagementlImageheaderMpxRECTYPE=CYilampid=63030 2192004
Page 1 ofl
I
i I I
I I
MV~
v I IIMTIIIL~
I ~
STATE OF GEORGIAl (X)UNTY OF MUlDI
I ~
IdmInIStler 0MhS In
being duIV sworn
__ilia In the
before me an 0IIIar duly UtIorized to
StIle of GeorgIa JennIfer M VIIbuena who abr
that the fads contained In her PetIIon for S4IIperate
IaWSampft are true and cortecent to the best Of
ITAft OP GEOMJA
her knowledge and
lIIIO 1M 1 cloy or - 2012
i~ Swom toJld subscr1bed beIore tbil ~ fI
httpcldaloetCQDIIVcbCaseManagementJImageheaderspxRECTYPE=ctilampid=63030 21912004
-----
Page 1 of3
EXHIBIT Jurtf--shy o 0
DI bullbullCOURfOPMUCOUIITY
STATlOP _ J ) ) CIVILAC11ION PILI
v J 1llUl1IOI)Qtv G3~_Kv I )
bull bull D
Upon coullldenltlDn ttl this ase upon ewfdencIe SIUbmIIttd bull provtded Or law
It aMjudgment tithe Court tIIIIt bull Decree ttl SIperIte MelntelNIIICe be
the
The Court custoctv tithe ChIIdrIft or the PartIes In ~WIIh the
IWtiIsSIUIeIliIIlt ~ wtIIch tied wIh the Court In deterrrIing chtIt
supfICIrt the Court IndII$ fcIIIov$
ChId suppaet In this mIbr Is dItennfned for two (2) chlldNn and the
CIlIIlSupport~ludl_hereIoiAIU8ldInceWlthOcGA 119-5-12
The NotMrI Gra1ncome Is $250000I1nOIth end the FMher1 Monthly
Gl-1ncoIM Is tl0OOO00m0nth The Parents CombINd AdjUllild Income is
$1uoooo he BIlle ChId Support 0blgIti0n (8CS011ur ttIe C1IIldren is
$2o35ao The MoIIers pro ortne acso 2000 WhIch equalS
$40700m0ntb end the pro -shere ttl tNt mount 1180 WhIch
$ll28OOnIOnth
bttpllcleJksnetCODIIWebCaseManagementImageheaderaspx1REClYPE=ctilampid~3181 2)12004
Page 2 of3
o o IIlIIddIIOn the FIltW is enIIted to IIiIIjuItmtItts for the chIIds heIIth
InIurIncIt MIl wort dIId Taking these adjuritment$lntO
JiCCOUIt the PrIiIIumptIyene ChIld Suppart AmrMIt $4eOlO fer the MGdIer and
$157480 fDrthe Hawevtr ttIt MottIer IS entkIId to addItIOnII nonshy
spedk ctevIItIon Ihe IlIOIIIG to bit exefCIIInt adcIItIonII QItlOdtat time
wII the QIIchn bullbull -it~ the PIrtIeS ]OInt phyIIaII cuMocIy 1MrusonI for
tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
induded In the PIretItI 0I1id SUpport wartcsheet TIIdng dIIs IddItfonII
cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
The FIIlherIs ordered to prwMde medIcII dentII ~ IIaideAt anct
- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
(18) old -COtMI iIICOIId
The Court IIIIISIIIImonr II tbIIows none
The SeallmettetIIIIed IIICo IIetwIen the dabId the 13
- u1S _01Y 20121amp fncorpOId III ~ and MIdI bull
bull - 80th PIIIndIrand DetelMIMt ordInId anIt commended to SUIclIy
GIfIPIr WIttI -1iWIIY pnMIIan 01 the DecretI 01 StpInte ~
DECReE eneAED this ~ rII MInh 2012
JuGge G V PIuIdI County SupIrtar Court I8uIdIng ludIdII CIItuIt ~
bttpf1cletksnetcomJWebCaseManagementJJmagebeaderaspxRBCTYPpound=CYiIampid~3181 2I9f2004
- ~-~~----~- --_~---
----~----~--~-~---------~- ~----
EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
EXHIBIT A
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER APPOINTING MAGISTRATE JUDGE TO HANDIJR
EMERGENCY MATIERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to eX parte family violence petitions This appoinunent is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
July 26 2010 through and including July 302010
SO ORDERED this 16mday ofJuly 2010
Marrin Enrique Valbuena Judge 0 t
Magistrate Court of Paulding County -laquo) c CI rr=10
Sr~ ~ l== C= roo) GI_shy11()7ns N (jZi Or z 0 c~x
J~ drmiddot lP(Ofded in Milute Book~ c II lt0
~ page~ Pauldillg C~nlyGeoqpa T g ( (
bull 1- 0 ell nns1llbday 01 i ~ mI Z CI
~ reva W Shelton Clerl4 of SupertorCaurt ~
EXHIBIT B
STATE OF GEORGIA
ORDER APPOINTIlG MAGISTRATE JlDGE TO IIA~DLE
EMERGENCY MATTERS I~ SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after dtlc diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is bereby appointed to act in such emergency matters which may
include but are not limited to ex pane family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCOA Scction 15-1-91 and is effective
January 192010 through and including January 222010
SO ORDERED this 13th day ofJanuary 2010
CONSENTED TO
~cbb Martin Enrique Valbuena Judge Magistrate Court ofPaulding County
EXHIBT C
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER AfPOINTlNG MAGISTRATE JUDGE TO HANDLE
EMERGENCY MATTERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to ex parte family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
January 21 2009 through and including January 232009
SO ORDERED this IlJjday ofJanuary 2009
CONSENTED TO _- Q
~~ IQS 0 c
lMartin Enrique Valbuena udge ~ Z
2Magistrate Court of Paulding County C 0 71 -gtlt Do ~ - sect _ ~
-() wZ fV UI ~
Piled and recorded In MInute Bookll- ~~
~ Pau_CounlyOeoIJlaRecOldJ ~dayor ampul~ mtli Treyena w SheIIon Clerk ofSuperlorCclull
~
~
I g
15
~
Q8
1
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-
ft
~ Iii 8
bull i
middot rI
~ i
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i
fl1
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1 I
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EXHIBT E
GPrIf IdA-tAf rift4 ~middotcll- ~e~
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Page I ofl
EXHIBIT H
w
I bull DIIIIIInt
) ) ) ) CMt -=noN fILl ) ) ) ) )
I
I f
I
I I
tManE~
~ IIMCe atPetltIohrIMls Petitian fer 5epInIte MImtInInce and adcIItIonII service of
_ summons In 1I1C8d GIIe Is IInby WItwed By so doing I
WJIuntarIty IUbmI myself the jUrtIdIctfon ofdie SUperfor Court of Pautdng COUnty
IIId any I may hive to such venue
INa_ 2012
gt ~JA
b I I
1IOtMfPU8UC=CCUflTY I i
oalnllnlall~ Itt
httpclebnetcomJWebCaseManagementlImageheaderMpxRECTYPE=CYilampid=63030 2192004
Page 1 ofl
I
i I I
I I
MV~
v I IIMTIIIL~
I ~
STATE OF GEORGIAl (X)UNTY OF MUlDI
I ~
IdmInIStler 0MhS In
being duIV sworn
__ilia In the
before me an 0IIIar duly UtIorized to
StIle of GeorgIa JennIfer M VIIbuena who abr
that the fads contained In her PetIIon for S4IIperate
IaWSampft are true and cortecent to the best Of
ITAft OP GEOMJA
her knowledge and
lIIIO 1M 1 cloy or - 2012
i~ Swom toJld subscr1bed beIore tbil ~ fI
httpcldaloetCQDIIVcbCaseManagementJImageheaderspxRECTYPE=ctilampid=63030 21912004
-----
Page 1 of3
EXHIBIT Jurtf--shy o 0
DI bullbullCOURfOPMUCOUIITY
STATlOP _ J ) ) CIVILAC11ION PILI
v J 1llUl1IOI)Qtv G3~_Kv I )
bull bull D
Upon coullldenltlDn ttl this ase upon ewfdencIe SIUbmIIttd bull provtded Or law
It aMjudgment tithe Court tIIIIt bull Decree ttl SIperIte MelntelNIIICe be
the
The Court custoctv tithe ChIIdrIft or the PartIes In ~WIIh the
IWtiIsSIUIeIliIIlt ~ wtIIch tied wIh the Court In deterrrIing chtIt
supfICIrt the Court IndII$ fcIIIov$
ChId suppaet In this mIbr Is dItennfned for two (2) chlldNn and the
CIlIIlSupport~ludl_hereIoiAIU8ldInceWlthOcGA 119-5-12
The NotMrI Gra1ncome Is $250000I1nOIth end the FMher1 Monthly
Gl-1ncoIM Is tl0OOO00m0nth The Parents CombINd AdjUllild Income is
$1uoooo he BIlle ChId Support 0blgIti0n (8CS011ur ttIe C1IIldren is
$2o35ao The MoIIers pro ortne acso 2000 WhIch equalS
$40700m0ntb end the pro -shere ttl tNt mount 1180 WhIch
$ll28OOnIOnth
bttpllcleJksnetCODIIWebCaseManagementImageheaderaspx1REClYPE=ctilampid~3181 2)12004
Page 2 of3
o o IIlIIddIIOn the FIltW is enIIted to IIiIIjuItmtItts for the chIIds heIIth
InIurIncIt MIl wort dIId Taking these adjuritment$lntO
JiCCOUIt the PrIiIIumptIyene ChIld Suppart AmrMIt $4eOlO fer the MGdIer and
$157480 fDrthe Hawevtr ttIt MottIer IS entkIId to addItIOnII nonshy
spedk ctevIItIon Ihe IlIOIIIG to bit exefCIIInt adcIItIonII QItlOdtat time
wII the QIIchn bullbull -it~ the PIrtIeS ]OInt phyIIaII cuMocIy 1MrusonI for
tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
induded In the PIretItI 0I1id SUpport wartcsheet TIIdng dIIs IddItfonII
cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
The FIIlherIs ordered to prwMde medIcII dentII ~ IIaideAt anct
- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
(18) old -COtMI iIICOIId
The Court IIIIISIIIImonr II tbIIows none
The SeallmettetIIIIed IIICo IIetwIen the dabId the 13
- u1S _01Y 20121amp fncorpOId III ~ and MIdI bull
bull - 80th PIIIndIrand DetelMIMt ordInId anIt commended to SUIclIy
GIfIPIr WIttI -1iWIIY pnMIIan 01 the DecretI 01 StpInte ~
DECReE eneAED this ~ rII MInh 2012
JuGge G V PIuIdI County SupIrtar Court I8uIdIng ludIdII CIItuIt ~
bttpf1cletksnetcomJWebCaseManagementJJmagebeaderaspxRBCTYPpound=CYiIampid~3181 2I9f2004
- ~-~~----~- --_~---
----~----~--~-~---------~- ~----
EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
EXHIBIT B
STATE OF GEORGIA
ORDER APPOINTIlG MAGISTRATE JlDGE TO IIA~DLE
EMERGENCY MATTERS I~ SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after dtlc diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is bereby appointed to act in such emergency matters which may
include but are not limited to ex pane family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCOA Scction 15-1-91 and is effective
January 192010 through and including January 222010
SO ORDERED this 13th day ofJanuary 2010
CONSENTED TO
~cbb Martin Enrique Valbuena Judge Magistrate Court ofPaulding County
EXHIBT C
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER AfPOINTlNG MAGISTRATE JUDGE TO HANDLE
EMERGENCY MATTERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to ex parte family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
January 21 2009 through and including January 232009
SO ORDERED this IlJjday ofJanuary 2009
CONSENTED TO _- Q
~~ IQS 0 c
lMartin Enrique Valbuena udge ~ Z
2Magistrate Court of Paulding County C 0 71 -gtlt Do ~ - sect _ ~
-() wZ fV UI ~
Piled and recorded In MInute Bookll- ~~
~ Pau_CounlyOeoIJlaRecOldJ ~dayor ampul~ mtli Treyena w SheIIon Clerk ofSuperlorCclull
~
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EXHIBT E
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EXHIBIT H
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I
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I
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tManE~
~ IIMCe atPetltIohrIMls Petitian fer 5epInIte MImtInInce and adcIItIonII service of
_ summons In 1I1C8d GIIe Is IInby WItwed By so doing I
WJIuntarIty IUbmI myself the jUrtIdIctfon ofdie SUperfor Court of Pautdng COUnty
IIId any I may hive to such venue
INa_ 2012
gt ~JA
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1IOtMfPU8UC=CCUflTY I i
oalnllnlall~ Itt
httpclebnetcomJWebCaseManagementlImageheaderMpxRECTYPE=CYilampid=63030 2192004
Page 1 ofl
I
i I I
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MV~
v I IIMTIIIL~
I ~
STATE OF GEORGIAl (X)UNTY OF MUlDI
I ~
IdmInIStler 0MhS In
being duIV sworn
__ilia In the
before me an 0IIIar duly UtIorized to
StIle of GeorgIa JennIfer M VIIbuena who abr
that the fads contained In her PetIIon for S4IIperate
IaWSampft are true and cortecent to the best Of
ITAft OP GEOMJA
her knowledge and
lIIIO 1M 1 cloy or - 2012
i~ Swom toJld subscr1bed beIore tbil ~ fI
httpcldaloetCQDIIVcbCaseManagementJImageheaderspxRECTYPE=ctilampid=63030 21912004
-----
Page 1 of3
EXHIBIT Jurtf--shy o 0
DI bullbullCOURfOPMUCOUIITY
STATlOP _ J ) ) CIVILAC11ION PILI
v J 1llUl1IOI)Qtv G3~_Kv I )
bull bull D
Upon coullldenltlDn ttl this ase upon ewfdencIe SIUbmIIttd bull provtded Or law
It aMjudgment tithe Court tIIIIt bull Decree ttl SIperIte MelntelNIIICe be
the
The Court custoctv tithe ChIIdrIft or the PartIes In ~WIIh the
IWtiIsSIUIeIliIIlt ~ wtIIch tied wIh the Court In deterrrIing chtIt
supfICIrt the Court IndII$ fcIIIov$
ChId suppaet In this mIbr Is dItennfned for two (2) chlldNn and the
CIlIIlSupport~ludl_hereIoiAIU8ldInceWlthOcGA 119-5-12
The NotMrI Gra1ncome Is $250000I1nOIth end the FMher1 Monthly
Gl-1ncoIM Is tl0OOO00m0nth The Parents CombINd AdjUllild Income is
$1uoooo he BIlle ChId Support 0blgIti0n (8CS011ur ttIe C1IIldren is
$2o35ao The MoIIers pro ortne acso 2000 WhIch equalS
$40700m0ntb end the pro -shere ttl tNt mount 1180 WhIch
$ll28OOnIOnth
bttpllcleJksnetCODIIWebCaseManagementImageheaderaspx1REClYPE=ctilampid~3181 2)12004
Page 2 of3
o o IIlIIddIIOn the FIltW is enIIted to IIiIIjuItmtItts for the chIIds heIIth
InIurIncIt MIl wort dIId Taking these adjuritment$lntO
JiCCOUIt the PrIiIIumptIyene ChIld Suppart AmrMIt $4eOlO fer the MGdIer and
$157480 fDrthe Hawevtr ttIt MottIer IS entkIId to addItIOnII nonshy
spedk ctevIItIon Ihe IlIOIIIG to bit exefCIIInt adcIItIonII QItlOdtat time
wII the QIIchn bullbull -it~ the PIrtIeS ]OInt phyIIaII cuMocIy 1MrusonI for
tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
induded In the PIretItI 0I1id SUpport wartcsheet TIIdng dIIs IddItfonII
cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
The FIIlherIs ordered to prwMde medIcII dentII ~ IIaideAt anct
- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
(18) old -COtMI iIICOIId
The Court IIIIISIIIImonr II tbIIows none
The SeallmettetIIIIed IIICo IIetwIen the dabId the 13
- u1S _01Y 20121amp fncorpOId III ~ and MIdI bull
bull - 80th PIIIndIrand DetelMIMt ordInId anIt commended to SUIclIy
GIfIPIr WIttI -1iWIIY pnMIIan 01 the DecretI 01 StpInte ~
DECReE eneAED this ~ rII MInh 2012
JuGge G V PIuIdI County SupIrtar Court I8uIdIng ludIdII CIItuIt ~
bttpf1cletksnetcomJWebCaseManagementJJmagebeaderaspxRBCTYPpound=CYiIampid~3181 2I9f2004
- ~-~~----~- --_~---
----~----~--~-~---------~- ~----
EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
EXHIBT C
IN THE SUPERIOR COURT FOR THE COUNTY OF PAULDING
STATE OF GEORGIA
ORDER AfPOINTlNG MAGISTRATE JUDGE TO HANDLE
EMERGENCY MATTERS IN SUPERIOR COURT
Should emergency matters arise which require the immediate attention of a
Superior Court Judge but after due diligence a Superior Court Judge cannot be located
within the circuit Judge Martin Enrique Valbuena Judge of the Magistrate Court of
Paulding County is hereby appointed to act in such emergency matters which may
include but are not limited to ex parte family violence petitions This appointment is
made pursuant to the Judicial Assistance Act OCGA Section 15-1-91 and is effective
January 21 2009 through and including January 232009
SO ORDERED this IlJjday ofJanuary 2009
CONSENTED TO _- Q
~~ IQS 0 c
lMartin Enrique Valbuena udge ~ Z
2Magistrate Court of Paulding County C 0 71 -gtlt Do ~ - sect _ ~
-() wZ fV UI ~
Piled and recorded In MInute Bookll- ~~
~ Pau_CounlyOeoIJlaRecOldJ ~dayor ampul~ mtli Treyena w SheIIon Clerk ofSuperlorCclull
~
~
I g
15
~
Q8
1
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-
ft
~ Iii 8
bull i
middot rI
~ i
~ E
i
fl1
1 I
middot)t
~ ~
~f i
1 I
I III
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1 t
deg
iii
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EXHIBT E
GPrIf IdA-tAf rift4 ~middotcll- ~e~
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EXHIBIT H
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I bull DIIIIIInt
) ) ) ) CMt -=noN fILl ) ) ) ) )
I
I f
I
I I
tManE~
~ IIMCe atPetltIohrIMls Petitian fer 5epInIte MImtInInce and adcIItIonII service of
_ summons In 1I1C8d GIIe Is IInby WItwed By so doing I
WJIuntarIty IUbmI myself the jUrtIdIctfon ofdie SUperfor Court of Pautdng COUnty
IIId any I may hive to such venue
INa_ 2012
gt ~JA
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1IOtMfPU8UC=CCUflTY I i
oalnllnlall~ Itt
httpclebnetcomJWebCaseManagementlImageheaderMpxRECTYPE=CYilampid=63030 2192004
Page 1 ofl
I
i I I
I I
MV~
v I IIMTIIIL~
I ~
STATE OF GEORGIAl (X)UNTY OF MUlDI
I ~
IdmInIStler 0MhS In
being duIV sworn
__ilia In the
before me an 0IIIar duly UtIorized to
StIle of GeorgIa JennIfer M VIIbuena who abr
that the fads contained In her PetIIon for S4IIperate
IaWSampft are true and cortecent to the best Of
ITAft OP GEOMJA
her knowledge and
lIIIO 1M 1 cloy or - 2012
i~ Swom toJld subscr1bed beIore tbil ~ fI
httpcldaloetCQDIIVcbCaseManagementJImageheaderspxRECTYPE=ctilampid=63030 21912004
-----
Page 1 of3
EXHIBIT Jurtf--shy o 0
DI bullbullCOURfOPMUCOUIITY
STATlOP _ J ) ) CIVILAC11ION PILI
v J 1llUl1IOI)Qtv G3~_Kv I )
bull bull D
Upon coullldenltlDn ttl this ase upon ewfdencIe SIUbmIIttd bull provtded Or law
It aMjudgment tithe Court tIIIIt bull Decree ttl SIperIte MelntelNIIICe be
the
The Court custoctv tithe ChIIdrIft or the PartIes In ~WIIh the
IWtiIsSIUIeIliIIlt ~ wtIIch tied wIh the Court In deterrrIing chtIt
supfICIrt the Court IndII$ fcIIIov$
ChId suppaet In this mIbr Is dItennfned for two (2) chlldNn and the
CIlIIlSupport~ludl_hereIoiAIU8ldInceWlthOcGA 119-5-12
The NotMrI Gra1ncome Is $250000I1nOIth end the FMher1 Monthly
Gl-1ncoIM Is tl0OOO00m0nth The Parents CombINd AdjUllild Income is
$1uoooo he BIlle ChId Support 0blgIti0n (8CS011ur ttIe C1IIldren is
$2o35ao The MoIIers pro ortne acso 2000 WhIch equalS
$40700m0ntb end the pro -shere ttl tNt mount 1180 WhIch
$ll28OOnIOnth
bttpllcleJksnetCODIIWebCaseManagementImageheaderaspx1REClYPE=ctilampid~3181 2)12004
Page 2 of3
o o IIlIIddIIOn the FIltW is enIIted to IIiIIjuItmtItts for the chIIds heIIth
InIurIncIt MIl wort dIId Taking these adjuritment$lntO
JiCCOUIt the PrIiIIumptIyene ChIld Suppart AmrMIt $4eOlO fer the MGdIer and
$157480 fDrthe Hawevtr ttIt MottIer IS entkIId to addItIOnII nonshy
spedk ctevIItIon Ihe IlIOIIIG to bit exefCIIInt adcIItIonII QItlOdtat time
wII the QIIchn bullbull -it~ the PIrtIeS ]OInt phyIIaII cuMocIy 1MrusonI for
tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
induded In the PIretItI 0I1id SUpport wartcsheet TIIdng dIIs IddItfonII
cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
The FIIlherIs ordered to prwMde medIcII dentII ~ IIaideAt anct
- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
(18) old -COtMI iIICOIId
The Court IIIIISIIIImonr II tbIIows none
The SeallmettetIIIIed IIICo IIetwIen the dabId the 13
- u1S _01Y 20121amp fncorpOId III ~ and MIdI bull
bull - 80th PIIIndIrand DetelMIMt ordInId anIt commended to SUIclIy
GIfIPIr WIttI -1iWIIY pnMIIan 01 the DecretI 01 StpInte ~
DECReE eneAED this ~ rII MInh 2012
JuGge G V PIuIdI County SupIrtar Court I8uIdIng ludIdII CIItuIt ~
bttpf1cletksnetcomJWebCaseManagementJJmagebeaderaspxRBCTYPpound=CYiIampid~3181 2I9f2004
- ~-~~----~- --_~---
----~----~--~-~---------~- ~----
EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
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EXHIBT E
GPrIf IdA-tAf rift4 ~middotcll- ~e~
J
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EXHIBIT H
w
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) ) ) ) CMt -=noN fILl ) ) ) ) )
I
I f
I
I I
tManE~
~ IIMCe atPetltIohrIMls Petitian fer 5epInIte MImtInInce and adcIItIonII service of
_ summons In 1I1C8d GIIe Is IInby WItwed By so doing I
WJIuntarIty IUbmI myself the jUrtIdIctfon ofdie SUperfor Court of Pautdng COUnty
IIId any I may hive to such venue
INa_ 2012
gt ~JA
b I I
1IOtMfPU8UC=CCUflTY I i
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Page 1 ofl
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I ~
STATE OF GEORGIAl (X)UNTY OF MUlDI
I ~
IdmInIStler 0MhS In
being duIV sworn
__ilia In the
before me an 0IIIar duly UtIorized to
StIle of GeorgIa JennIfer M VIIbuena who abr
that the fads contained In her PetIIon for S4IIperate
IaWSampft are true and cortecent to the best Of
ITAft OP GEOMJA
her knowledge and
lIIIO 1M 1 cloy or - 2012
i~ Swom toJld subscr1bed beIore tbil ~ fI
httpcldaloetCQDIIVcbCaseManagementJImageheaderspxRECTYPE=ctilampid=63030 21912004
-----
Page 1 of3
EXHIBIT Jurtf--shy o 0
DI bullbullCOURfOPMUCOUIITY
STATlOP _ J ) ) CIVILAC11ION PILI
v J 1llUl1IOI)Qtv G3~_Kv I )
bull bull D
Upon coullldenltlDn ttl this ase upon ewfdencIe SIUbmIIttd bull provtded Or law
It aMjudgment tithe Court tIIIIt bull Decree ttl SIperIte MelntelNIIICe be
the
The Court custoctv tithe ChIIdrIft or the PartIes In ~WIIh the
IWtiIsSIUIeIliIIlt ~ wtIIch tied wIh the Court In deterrrIing chtIt
supfICIrt the Court IndII$ fcIIIov$
ChId suppaet In this mIbr Is dItennfned for two (2) chlldNn and the
CIlIIlSupport~ludl_hereIoiAIU8ldInceWlthOcGA 119-5-12
The NotMrI Gra1ncome Is $250000I1nOIth end the FMher1 Monthly
Gl-1ncoIM Is tl0OOO00m0nth The Parents CombINd AdjUllild Income is
$1uoooo he BIlle ChId Support 0blgIti0n (8CS011ur ttIe C1IIldren is
$2o35ao The MoIIers pro ortne acso 2000 WhIch equalS
$40700m0ntb end the pro -shere ttl tNt mount 1180 WhIch
$ll28OOnIOnth
bttpllcleJksnetCODIIWebCaseManagementImageheaderaspx1REClYPE=ctilampid~3181 2)12004
Page 2 of3
o o IIlIIddIIOn the FIltW is enIIted to IIiIIjuItmtItts for the chIIds heIIth
InIurIncIt MIl wort dIId Taking these adjuritment$lntO
JiCCOUIt the PrIiIIumptIyene ChIld Suppart AmrMIt $4eOlO fer the MGdIer and
$157480 fDrthe Hawevtr ttIt MottIer IS entkIId to addItIOnII nonshy
spedk ctevIItIon Ihe IlIOIIIG to bit exefCIIInt adcIItIonII QItlOdtat time
wII the QIIchn bullbull -it~ the PIrtIeS ]OInt phyIIaII cuMocIy 1MrusonI for
tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
induded In the PIretItI 0I1id SUpport wartcsheet TIIdng dIIs IddItfonII
cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
The FIIlherIs ordered to prwMde medIcII dentII ~ IIaideAt anct
- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
(18) old -COtMI iIICOIId
The Court IIIIISIIIImonr II tbIIows none
The SeallmettetIIIIed IIICo IIetwIen the dabId the 13
- u1S _01Y 20121amp fncorpOId III ~ and MIdI bull
bull - 80th PIIIndIrand DetelMIMt ordInId anIt commended to SUIclIy
GIfIPIr WIttI -1iWIIY pnMIIan 01 the DecretI 01 StpInte ~
DECReE eneAED this ~ rII MInh 2012
JuGge G V PIuIdI County SupIrtar Court I8uIdIng ludIdII CIItuIt ~
bttpf1cletksnetcomJWebCaseManagementJJmagebeaderaspxRBCTYPpound=CYiIampid~3181 2I9f2004
- ~-~~----~- --_~---
----~----~--~-~---------~- ~----
EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
EXHIBT E
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Page I ofl
EXHIBIT H
w
I bull DIIIIIInt
) ) ) ) CMt -=noN fILl ) ) ) ) )
I
I f
I
I I
tManE~
~ IIMCe atPetltIohrIMls Petitian fer 5epInIte MImtInInce and adcIItIonII service of
_ summons In 1I1C8d GIIe Is IInby WItwed By so doing I
WJIuntarIty IUbmI myself the jUrtIdIctfon ofdie SUperfor Court of Pautdng COUnty
IIId any I may hive to such venue
INa_ 2012
gt ~JA
b I I
1IOtMfPU8UC=CCUflTY I i
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httpclebnetcomJWebCaseManagementlImageheaderMpxRECTYPE=CYilampid=63030 2192004
Page 1 ofl
I
i I I
I I
MV~
v I IIMTIIIL~
I ~
STATE OF GEORGIAl (X)UNTY OF MUlDI
I ~
IdmInIStler 0MhS In
being duIV sworn
__ilia In the
before me an 0IIIar duly UtIorized to
StIle of GeorgIa JennIfer M VIIbuena who abr
that the fads contained In her PetIIon for S4IIperate
IaWSampft are true and cortecent to the best Of
ITAft OP GEOMJA
her knowledge and
lIIIO 1M 1 cloy or - 2012
i~ Swom toJld subscr1bed beIore tbil ~ fI
httpcldaloetCQDIIVcbCaseManagementJImageheaderspxRECTYPE=ctilampid=63030 21912004
-----
Page 1 of3
EXHIBIT Jurtf--shy o 0
DI bullbullCOURfOPMUCOUIITY
STATlOP _ J ) ) CIVILAC11ION PILI
v J 1llUl1IOI)Qtv G3~_Kv I )
bull bull D
Upon coullldenltlDn ttl this ase upon ewfdencIe SIUbmIIttd bull provtded Or law
It aMjudgment tithe Court tIIIIt bull Decree ttl SIperIte MelntelNIIICe be
the
The Court custoctv tithe ChIIdrIft or the PartIes In ~WIIh the
IWtiIsSIUIeIliIIlt ~ wtIIch tied wIh the Court In deterrrIing chtIt
supfICIrt the Court IndII$ fcIIIov$
ChId suppaet In this mIbr Is dItennfned for two (2) chlldNn and the
CIlIIlSupport~ludl_hereIoiAIU8ldInceWlthOcGA 119-5-12
The NotMrI Gra1ncome Is $250000I1nOIth end the FMher1 Monthly
Gl-1ncoIM Is tl0OOO00m0nth The Parents CombINd AdjUllild Income is
$1uoooo he BIlle ChId Support 0blgIti0n (8CS011ur ttIe C1IIldren is
$2o35ao The MoIIers pro ortne acso 2000 WhIch equalS
$40700m0ntb end the pro -shere ttl tNt mount 1180 WhIch
$ll28OOnIOnth
bttpllcleJksnetCODIIWebCaseManagementImageheaderaspx1REClYPE=ctilampid~3181 2)12004
Page 2 of3
o o IIlIIddIIOn the FIltW is enIIted to IIiIIjuItmtItts for the chIIds heIIth
InIurIncIt MIl wort dIId Taking these adjuritment$lntO
JiCCOUIt the PrIiIIumptIyene ChIld Suppart AmrMIt $4eOlO fer the MGdIer and
$157480 fDrthe Hawevtr ttIt MottIer IS entkIId to addItIOnII nonshy
spedk ctevIItIon Ihe IlIOIIIG to bit exefCIIInt adcIItIonII QItlOdtat time
wII the QIIchn bullbull -it~ the PIrtIeS ]OInt phyIIaII cuMocIy 1MrusonI for
tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
induded In the PIretItI 0I1id SUpport wartcsheet TIIdng dIIs IddItfonII
cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
The FIIlherIs ordered to prwMde medIcII dentII ~ IIaideAt anct
- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
(18) old -COtMI iIICOIId
The Court IIIIISIIIImonr II tbIIows none
The SeallmettetIIIIed IIICo IIetwIen the dabId the 13
- u1S _01Y 20121amp fncorpOId III ~ and MIdI bull
bull - 80th PIIIndIrand DetelMIMt ordInId anIt commended to SUIclIy
GIfIPIr WIttI -1iWIIY pnMIIan 01 the DecretI 01 StpInte ~
DECReE eneAED this ~ rII MInh 2012
JuGge G V PIuIdI County SupIrtar Court I8uIdIng ludIdII CIItuIt ~
bttpf1cletksnetcomJWebCaseManagementJJmagebeaderaspxRBCTYPpound=CYiIampid~3181 2I9f2004
- ~-~~----~- --_~---
----~----~--~-~---------~- ~----
EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
Page I ofl
EXHIBIT H
w
I bull DIIIIIInt
) ) ) ) CMt -=noN fILl ) ) ) ) )
I
I f
I
I I
tManE~
~ IIMCe atPetltIohrIMls Petitian fer 5epInIte MImtInInce and adcIItIonII service of
_ summons In 1I1C8d GIIe Is IInby WItwed By so doing I
WJIuntarIty IUbmI myself the jUrtIdIctfon ofdie SUperfor Court of Pautdng COUnty
IIId any I may hive to such venue
INa_ 2012
gt ~JA
b I I
1IOtMfPU8UC=CCUflTY I i
oalnllnlall~ Itt
httpclebnetcomJWebCaseManagementlImageheaderMpxRECTYPE=CYilampid=63030 2192004
Page 1 ofl
I
i I I
I I
MV~
v I IIMTIIIL~
I ~
STATE OF GEORGIAl (X)UNTY OF MUlDI
I ~
IdmInIStler 0MhS In
being duIV sworn
__ilia In the
before me an 0IIIar duly UtIorized to
StIle of GeorgIa JennIfer M VIIbuena who abr
that the fads contained In her PetIIon for S4IIperate
IaWSampft are true and cortecent to the best Of
ITAft OP GEOMJA
her knowledge and
lIIIO 1M 1 cloy or - 2012
i~ Swom toJld subscr1bed beIore tbil ~ fI
httpcldaloetCQDIIVcbCaseManagementJImageheaderspxRECTYPE=ctilampid=63030 21912004
-----
Page 1 of3
EXHIBIT Jurtf--shy o 0
DI bullbullCOURfOPMUCOUIITY
STATlOP _ J ) ) CIVILAC11ION PILI
v J 1llUl1IOI)Qtv G3~_Kv I )
bull bull D
Upon coullldenltlDn ttl this ase upon ewfdencIe SIUbmIIttd bull provtded Or law
It aMjudgment tithe Court tIIIIt bull Decree ttl SIperIte MelntelNIIICe be
the
The Court custoctv tithe ChIIdrIft or the PartIes In ~WIIh the
IWtiIsSIUIeIliIIlt ~ wtIIch tied wIh the Court In deterrrIing chtIt
supfICIrt the Court IndII$ fcIIIov$
ChId suppaet In this mIbr Is dItennfned for two (2) chlldNn and the
CIlIIlSupport~ludl_hereIoiAIU8ldInceWlthOcGA 119-5-12
The NotMrI Gra1ncome Is $250000I1nOIth end the FMher1 Monthly
Gl-1ncoIM Is tl0OOO00m0nth The Parents CombINd AdjUllild Income is
$1uoooo he BIlle ChId Support 0blgIti0n (8CS011ur ttIe C1IIldren is
$2o35ao The MoIIers pro ortne acso 2000 WhIch equalS
$40700m0ntb end the pro -shere ttl tNt mount 1180 WhIch
$ll28OOnIOnth
bttpllcleJksnetCODIIWebCaseManagementImageheaderaspx1REClYPE=ctilampid~3181 2)12004
Page 2 of3
o o IIlIIddIIOn the FIltW is enIIted to IIiIIjuItmtItts for the chIIds heIIth
InIurIncIt MIl wort dIId Taking these adjuritment$lntO
JiCCOUIt the PrIiIIumptIyene ChIld Suppart AmrMIt $4eOlO fer the MGdIer and
$157480 fDrthe Hawevtr ttIt MottIer IS entkIId to addItIOnII nonshy
spedk ctevIItIon Ihe IlIOIIIG to bit exefCIIInt adcIItIonII QItlOdtat time
wII the QIIchn bullbull -it~ the PIrtIeS ]OInt phyIIaII cuMocIy 1MrusonI for
tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
induded In the PIretItI 0I1id SUpport wartcsheet TIIdng dIIs IddItfonII
cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
The FIIlherIs ordered to prwMde medIcII dentII ~ IIaideAt anct
- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
(18) old -COtMI iIICOIId
The Court IIIIISIIIImonr II tbIIows none
The SeallmettetIIIIed IIICo IIetwIen the dabId the 13
- u1S _01Y 20121amp fncorpOId III ~ and MIdI bull
bull - 80th PIIIndIrand DetelMIMt ordInId anIt commended to SUIclIy
GIfIPIr WIttI -1iWIIY pnMIIan 01 the DecretI 01 StpInte ~
DECReE eneAED this ~ rII MInh 2012
JuGge G V PIuIdI County SupIrtar Court I8uIdIng ludIdII CIItuIt ~
bttpf1cletksnetcomJWebCaseManagementJJmagebeaderaspxRBCTYPpound=CYiIampid~3181 2I9f2004
- ~-~~----~- --_~---
----~----~--~-~---------~- ~----
EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
Page I ofl
EXHIBIT H
w
I bull DIIIIIInt
) ) ) ) CMt -=noN fILl ) ) ) ) )
I
I f
I
I I
tManE~
~ IIMCe atPetltIohrIMls Petitian fer 5epInIte MImtInInce and adcIItIonII service of
_ summons In 1I1C8d GIIe Is IInby WItwed By so doing I
WJIuntarIty IUbmI myself the jUrtIdIctfon ofdie SUperfor Court of Pautdng COUnty
IIId any I may hive to such venue
INa_ 2012
gt ~JA
b I I
1IOtMfPU8UC=CCUflTY I i
oalnllnlall~ Itt
httpclebnetcomJWebCaseManagementlImageheaderMpxRECTYPE=CYilampid=63030 2192004
Page 1 ofl
I
i I I
I I
MV~
v I IIMTIIIL~
I ~
STATE OF GEORGIAl (X)UNTY OF MUlDI
I ~
IdmInIStler 0MhS In
being duIV sworn
__ilia In the
before me an 0IIIar duly UtIorized to
StIle of GeorgIa JennIfer M VIIbuena who abr
that the fads contained In her PetIIon for S4IIperate
IaWSampft are true and cortecent to the best Of
ITAft OP GEOMJA
her knowledge and
lIIIO 1M 1 cloy or - 2012
i~ Swom toJld subscr1bed beIore tbil ~ fI
httpcldaloetCQDIIVcbCaseManagementJImageheaderspxRECTYPE=ctilampid=63030 21912004
-----
Page 1 of3
EXHIBIT Jurtf--shy o 0
DI bullbullCOURfOPMUCOUIITY
STATlOP _ J ) ) CIVILAC11ION PILI
v J 1llUl1IOI)Qtv G3~_Kv I )
bull bull D
Upon coullldenltlDn ttl this ase upon ewfdencIe SIUbmIIttd bull provtded Or law
It aMjudgment tithe Court tIIIIt bull Decree ttl SIperIte MelntelNIIICe be
the
The Court custoctv tithe ChIIdrIft or the PartIes In ~WIIh the
IWtiIsSIUIeIliIIlt ~ wtIIch tied wIh the Court In deterrrIing chtIt
supfICIrt the Court IndII$ fcIIIov$
ChId suppaet In this mIbr Is dItennfned for two (2) chlldNn and the
CIlIIlSupport~ludl_hereIoiAIU8ldInceWlthOcGA 119-5-12
The NotMrI Gra1ncome Is $250000I1nOIth end the FMher1 Monthly
Gl-1ncoIM Is tl0OOO00m0nth The Parents CombINd AdjUllild Income is
$1uoooo he BIlle ChId Support 0blgIti0n (8CS011ur ttIe C1IIldren is
$2o35ao The MoIIers pro ortne acso 2000 WhIch equalS
$40700m0ntb end the pro -shere ttl tNt mount 1180 WhIch
$ll28OOnIOnth
bttpllcleJksnetCODIIWebCaseManagementImageheaderaspx1REClYPE=ctilampid~3181 2)12004
Page 2 of3
o o IIlIIddIIOn the FIltW is enIIted to IIiIIjuItmtItts for the chIIds heIIth
InIurIncIt MIl wort dIId Taking these adjuritment$lntO
JiCCOUIt the PrIiIIumptIyene ChIld Suppart AmrMIt $4eOlO fer the MGdIer and
$157480 fDrthe Hawevtr ttIt MottIer IS entkIId to addItIOnII nonshy
spedk ctevIItIon Ihe IlIOIIIG to bit exefCIIInt adcIItIonII QItlOdtat time
wII the QIIchn bullbull -it~ the PIrtIeS ]OInt phyIIaII cuMocIy 1MrusonI for
tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
induded In the PIretItI 0I1id SUpport wartcsheet TIIdng dIIs IddItfonII
cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
The FIIlherIs ordered to prwMde medIcII dentII ~ IIaideAt anct
- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
(18) old -COtMI iIICOIId
The Court IIIIISIIIImonr II tbIIows none
The SeallmettetIIIIed IIICo IIetwIen the dabId the 13
- u1S _01Y 20121amp fncorpOId III ~ and MIdI bull
bull - 80th PIIIndIrand DetelMIMt ordInId anIt commended to SUIclIy
GIfIPIr WIttI -1iWIIY pnMIIan 01 the DecretI 01 StpInte ~
DECReE eneAED this ~ rII MInh 2012
JuGge G V PIuIdI County SupIrtar Court I8uIdIng ludIdII CIItuIt ~
bttpf1cletksnetcomJWebCaseManagementJJmagebeaderaspxRBCTYPpound=CYiIampid~3181 2I9f2004
- ~-~~----~- --_~---
----~----~--~-~---------~- ~----
EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
Page I ofl
EXHIBIT H
w
I bull DIIIIIInt
) ) ) ) CMt -=noN fILl ) ) ) ) )
I
I f
I
I I
tManE~
~ IIMCe atPetltIohrIMls Petitian fer 5epInIte MImtInInce and adcIItIonII service of
_ summons In 1I1C8d GIIe Is IInby WItwed By so doing I
WJIuntarIty IUbmI myself the jUrtIdIctfon ofdie SUperfor Court of Pautdng COUnty
IIId any I may hive to such venue
INa_ 2012
gt ~JA
b I I
1IOtMfPU8UC=CCUflTY I i
oalnllnlall~ Itt
httpclebnetcomJWebCaseManagementlImageheaderMpxRECTYPE=CYilampid=63030 2192004
Page 1 ofl
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i I I
I I
MV~
v I IIMTIIIL~
I ~
STATE OF GEORGIAl (X)UNTY OF MUlDI
I ~
IdmInIStler 0MhS In
being duIV sworn
__ilia In the
before me an 0IIIar duly UtIorized to
StIle of GeorgIa JennIfer M VIIbuena who abr
that the fads contained In her PetIIon for S4IIperate
IaWSampft are true and cortecent to the best Of
ITAft OP GEOMJA
her knowledge and
lIIIO 1M 1 cloy or - 2012
i~ Swom toJld subscr1bed beIore tbil ~ fI
httpcldaloetCQDIIVcbCaseManagementJImageheaderspxRECTYPE=ctilampid=63030 21912004
-----
Page 1 of3
EXHIBIT Jurtf--shy o 0
DI bullbullCOURfOPMUCOUIITY
STATlOP _ J ) ) CIVILAC11ION PILI
v J 1llUl1IOI)Qtv G3~_Kv I )
bull bull D
Upon coullldenltlDn ttl this ase upon ewfdencIe SIUbmIIttd bull provtded Or law
It aMjudgment tithe Court tIIIIt bull Decree ttl SIperIte MelntelNIIICe be
the
The Court custoctv tithe ChIIdrIft or the PartIes In ~WIIh the
IWtiIsSIUIeIliIIlt ~ wtIIch tied wIh the Court In deterrrIing chtIt
supfICIrt the Court IndII$ fcIIIov$
ChId suppaet In this mIbr Is dItennfned for two (2) chlldNn and the
CIlIIlSupport~ludl_hereIoiAIU8ldInceWlthOcGA 119-5-12
The NotMrI Gra1ncome Is $250000I1nOIth end the FMher1 Monthly
Gl-1ncoIM Is tl0OOO00m0nth The Parents CombINd AdjUllild Income is
$1uoooo he BIlle ChId Support 0blgIti0n (8CS011ur ttIe C1IIldren is
$2o35ao The MoIIers pro ortne acso 2000 WhIch equalS
$40700m0ntb end the pro -shere ttl tNt mount 1180 WhIch
$ll28OOnIOnth
bttpllcleJksnetCODIIWebCaseManagementImageheaderaspx1REClYPE=ctilampid~3181 2)12004
Page 2 of3
o o IIlIIddIIOn the FIltW is enIIted to IIiIIjuItmtItts for the chIIds heIIth
InIurIncIt MIl wort dIId Taking these adjuritment$lntO
JiCCOUIt the PrIiIIumptIyene ChIld Suppart AmrMIt $4eOlO fer the MGdIer and
$157480 fDrthe Hawevtr ttIt MottIer IS entkIId to addItIOnII nonshy
spedk ctevIItIon Ihe IlIOIIIG to bit exefCIIInt adcIItIonII QItlOdtat time
wII the QIIchn bullbull -it~ the PIrtIeS ]OInt phyIIaII cuMocIy 1MrusonI for
tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
induded In the PIretItI 0I1id SUpport wartcsheet TIIdng dIIs IddItfonII
cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
The FIIlherIs ordered to prwMde medIcII dentII ~ IIaideAt anct
- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
(18) old -COtMI iIICOIId
The Court IIIIISIIIImonr II tbIIows none
The SeallmettetIIIIed IIICo IIetwIen the dabId the 13
- u1S _01Y 20121amp fncorpOId III ~ and MIdI bull
bull - 80th PIIIndIrand DetelMIMt ordInId anIt commended to SUIclIy
GIfIPIr WIttI -1iWIIY pnMIIan 01 the DecretI 01 StpInte ~
DECReE eneAED this ~ rII MInh 2012
JuGge G V PIuIdI County SupIrtar Court I8uIdIng ludIdII CIItuIt ~
bttpf1cletksnetcomJWebCaseManagementJJmagebeaderaspxRBCTYPpound=CYiIampid~3181 2I9f2004
- ~-~~----~- --_~---
----~----~--~-~---------~- ~----
EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
Page 1 ofl
I
i I I
I I
MV~
v I IIMTIIIL~
I ~
STATE OF GEORGIAl (X)UNTY OF MUlDI
I ~
IdmInIStler 0MhS In
being duIV sworn
__ilia In the
before me an 0IIIar duly UtIorized to
StIle of GeorgIa JennIfer M VIIbuena who abr
that the fads contained In her PetIIon for S4IIperate
IaWSampft are true and cortecent to the best Of
ITAft OP GEOMJA
her knowledge and
lIIIO 1M 1 cloy or - 2012
i~ Swom toJld subscr1bed beIore tbil ~ fI
httpcldaloetCQDIIVcbCaseManagementJImageheaderspxRECTYPE=ctilampid=63030 21912004
-----
Page 1 of3
EXHIBIT Jurtf--shy o 0
DI bullbullCOURfOPMUCOUIITY
STATlOP _ J ) ) CIVILAC11ION PILI
v J 1llUl1IOI)Qtv G3~_Kv I )
bull bull D
Upon coullldenltlDn ttl this ase upon ewfdencIe SIUbmIIttd bull provtded Or law
It aMjudgment tithe Court tIIIIt bull Decree ttl SIperIte MelntelNIIICe be
the
The Court custoctv tithe ChIIdrIft or the PartIes In ~WIIh the
IWtiIsSIUIeIliIIlt ~ wtIIch tied wIh the Court In deterrrIing chtIt
supfICIrt the Court IndII$ fcIIIov$
ChId suppaet In this mIbr Is dItennfned for two (2) chlldNn and the
CIlIIlSupport~ludl_hereIoiAIU8ldInceWlthOcGA 119-5-12
The NotMrI Gra1ncome Is $250000I1nOIth end the FMher1 Monthly
Gl-1ncoIM Is tl0OOO00m0nth The Parents CombINd AdjUllild Income is
$1uoooo he BIlle ChId Support 0blgIti0n (8CS011ur ttIe C1IIldren is
$2o35ao The MoIIers pro ortne acso 2000 WhIch equalS
$40700m0ntb end the pro -shere ttl tNt mount 1180 WhIch
$ll28OOnIOnth
bttpllcleJksnetCODIIWebCaseManagementImageheaderaspx1REClYPE=ctilampid~3181 2)12004
Page 2 of3
o o IIlIIddIIOn the FIltW is enIIted to IIiIIjuItmtItts for the chIIds heIIth
InIurIncIt MIl wort dIId Taking these adjuritment$lntO
JiCCOUIt the PrIiIIumptIyene ChIld Suppart AmrMIt $4eOlO fer the MGdIer and
$157480 fDrthe Hawevtr ttIt MottIer IS entkIId to addItIOnII nonshy
spedk ctevIItIon Ihe IlIOIIIG to bit exefCIIInt adcIItIonII QItlOdtat time
wII the QIIchn bullbull -it~ the PIrtIeS ]OInt phyIIaII cuMocIy 1MrusonI for
tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
induded In the PIretItI 0I1id SUpport wartcsheet TIIdng dIIs IddItfonII
cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
The FIIlherIs ordered to prwMde medIcII dentII ~ IIaideAt anct
- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
(18) old -COtMI iIICOIId
The Court IIIIISIIIImonr II tbIIows none
The SeallmettetIIIIed IIICo IIetwIen the dabId the 13
- u1S _01Y 20121amp fncorpOId III ~ and MIdI bull
bull - 80th PIIIndIrand DetelMIMt ordInId anIt commended to SUIclIy
GIfIPIr WIttI -1iWIIY pnMIIan 01 the DecretI 01 StpInte ~
DECReE eneAED this ~ rII MInh 2012
JuGge G V PIuIdI County SupIrtar Court I8uIdIng ludIdII CIItuIt ~
bttpf1cletksnetcomJWebCaseManagementJJmagebeaderaspxRBCTYPpound=CYiIampid~3181 2I9f2004
- ~-~~----~- --_~---
----~----~--~-~---------~- ~----
EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
-----
Page 1 of3
EXHIBIT Jurtf--shy o 0
DI bullbullCOURfOPMUCOUIITY
STATlOP _ J ) ) CIVILAC11ION PILI
v J 1llUl1IOI)Qtv G3~_Kv I )
bull bull D
Upon coullldenltlDn ttl this ase upon ewfdencIe SIUbmIIttd bull provtded Or law
It aMjudgment tithe Court tIIIIt bull Decree ttl SIperIte MelntelNIIICe be
the
The Court custoctv tithe ChIIdrIft or the PartIes In ~WIIh the
IWtiIsSIUIeIliIIlt ~ wtIIch tied wIh the Court In deterrrIing chtIt
supfICIrt the Court IndII$ fcIIIov$
ChId suppaet In this mIbr Is dItennfned for two (2) chlldNn and the
CIlIIlSupport~ludl_hereIoiAIU8ldInceWlthOcGA 119-5-12
The NotMrI Gra1ncome Is $250000I1nOIth end the FMher1 Monthly
Gl-1ncoIM Is tl0OOO00m0nth The Parents CombINd AdjUllild Income is
$1uoooo he BIlle ChId Support 0blgIti0n (8CS011ur ttIe C1IIldren is
$2o35ao The MoIIers pro ortne acso 2000 WhIch equalS
$40700m0ntb end the pro -shere ttl tNt mount 1180 WhIch
$ll28OOnIOnth
bttpllcleJksnetCODIIWebCaseManagementImageheaderaspx1REClYPE=ctilampid~3181 2)12004
Page 2 of3
o o IIlIIddIIOn the FIltW is enIIted to IIiIIjuItmtItts for the chIIds heIIth
InIurIncIt MIl wort dIId Taking these adjuritment$lntO
JiCCOUIt the PrIiIIumptIyene ChIld Suppart AmrMIt $4eOlO fer the MGdIer and
$157480 fDrthe Hawevtr ttIt MottIer IS entkIId to addItIOnII nonshy
spedk ctevIItIon Ihe IlIOIIIG to bit exefCIIInt adcIItIonII QItlOdtat time
wII the QIIchn bullbull -it~ the PIrtIeS ]OInt phyIIaII cuMocIy 1MrusonI for
tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
induded In the PIretItI 0I1id SUpport wartcsheet TIIdng dIIs IddItfonII
cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
The FIIlherIs ordered to prwMde medIcII dentII ~ IIaideAt anct
- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
(18) old -COtMI iIICOIId
The Court IIIIISIIIImonr II tbIIows none
The SeallmettetIIIIed IIICo IIetwIen the dabId the 13
- u1S _01Y 20121amp fncorpOId III ~ and MIdI bull
bull - 80th PIIIndIrand DetelMIMt ordInId anIt commended to SUIclIy
GIfIPIr WIttI -1iWIIY pnMIIan 01 the DecretI 01 StpInte ~
DECReE eneAED this ~ rII MInh 2012
JuGge G V PIuIdI County SupIrtar Court I8uIdIng ludIdII CIItuIt ~
bttpf1cletksnetcomJWebCaseManagementJJmagebeaderaspxRBCTYPpound=CYiIampid~3181 2I9f2004
- ~-~~----~- --_~---
----~----~--~-~---------~- ~----
EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
Page 2 of3
o o IIlIIddIIOn the FIltW is enIIted to IIiIIjuItmtItts for the chIIds heIIth
InIurIncIt MIl wort dIId Taking these adjuritment$lntO
JiCCOUIt the PrIiIIumptIyene ChIld Suppart AmrMIt $4eOlO fer the MGdIer and
$157480 fDrthe Hawevtr ttIt MottIer IS entkIId to addItIOnII nonshy
spedk ctevIItIon Ihe IlIOIIIG to bit exefCIIInt adcIItIonII QItlOdtat time
wII the QIIchn bullbull -it~ the PIrtIeS ]OInt phyIIaII cuMocIy 1MrusonI for
tNs nan-tpIlCIIIc dllItkIIla _Itthe PnasurnpUye ON Support Amount
induded In the PIretItI 0I1id SUpport wartcsheet TIIdng dIIs IddItfonII
cIeyenSIlioI _ ICICOUnt the FInII ChIld Support Amount Is $000 for the I4cIther and
$157500 for tM Palbel IbIInItore the MoIMr not MIce rtgUIIr rncwtthIy
eMS ort mentI to the NhIr
The FIIlherIs ordered to prwMde medIcII dentII ~ IIaideAt anct
- Ior the 0IIIdNft untif they gIIICfuIeIe fil)m ~ tchooI or tum
(18) old -COtMI iIICOIId
The Court IIIIISIIIImonr II tbIIows none
The SeallmettetIIIIed IIICo IIetwIen the dabId the 13
- u1S _01Y 20121amp fncorpOId III ~ and MIdI bull
bull - 80th PIIIndIrand DetelMIMt ordInId anIt commended to SUIclIy
GIfIPIr WIttI -1iWIIY pnMIIan 01 the DecretI 01 StpInte ~
DECReE eneAED this ~ rII MInh 2012
JuGge G V PIuIdI County SupIrtar Court I8uIdIng ludIdII CIItuIt ~
bttpf1cletksnetcomJWebCaseManagementJJmagebeaderaspxRBCTYPpound=CYiIampid~3181 2I9f2004
- ~-~~----~- --_~---
----~----~--~-~---------~- ~----
EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
EXHIBIT K
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009
Page 1 of1
IN THE SUPEJUOR COURT OP PAULDING COUNTY STATE OF GEORGIA
MICHAEL L LOWE ) )
Plaintiff v ) CIVIL ACTlONFlLE
) NOOS-CV-1l24-JO EUSA M LOWE )
) lgtefendut )
CERTIFICATE OF SERVICE
COMES NOW the former Defendant EUsa L Lowe and certifies that she has filed tbe following dooumenlSand pleadings in the above-captioned case and shows that she has mailed via rUSl c_ mail copies of said pleadings to Martin Valbuma attorney of reoord for the former Plaintiff Judge James Osborne and ChiefJudge Tony Beavers
MOTION TORECUSI JUDGE JAMES OS80amp4pound AND OTHER PAULDING SUPERIORCOURTJUDGES fROM PARTICIPAnON IN CASE WHERE SANCTIONS AGAJNSTPRO TEM SUPERIOR COURT ItIOOE ARE TO BE CONsmDED
Said documents were mailed via US First Class Mailto the above-named addrepoundsees as follows
Martin Enrique Valbuena Honorable James R Osborne J13 Village Walk Suite B Judge Paulding Superior CQurt PO 8ltraquot 1125 280 Constitution Blvd DaUas Georgia 30132 DallasOA )0t32
Honorable Tonny S Beavers ChiefJudge Paulding Superior Court 280 Constitution Blvd Dellas vA ltH 32
Submitted thi~ day QfMarch 2011
~~ ProSe
219 Crossroad ESf4lles Drive Newnan CiA l026S (404) 104-7058
httpclerksnttcomlwebcasemanagementImageheader aspxRECTYPE = Ci~id= 534265ampCstl 5152009