William Windsor sues The Delaney at Lake Waco Nursing Home - Managed by Life Care Services

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A lawsuit has been filed by William M. Windsor against The Delaney at Lake Waco, a senior living facility in Waco, Texas. Bill Windsor filed the lawsuit after he was sued by The Delaney at Lake Waco in an effort to block his freedom of speech and freedom of the press. Cause Number 2021-3814-5 in McLennan County District Court in Waco, Texas...

ORIGINAL ANSWER

1.                  WILLIAM WINDSOR (“THIRD-PARTY DEFENDANT” or “WINDSOR”) files this Answer to THE DELANEY AT LAKE WACO’s Third-Party Petition, and in support thereof, would respectfully shows the Court as follows:

GENERAL DENIAL

2.                  WINDSOR generally denies the allegations contained in Plaintiff’s Petition and any amendments and/or supplements thereto as permitted by Rule 92 of the TEXAS RULES OF CIVIL PROCEDURE and requests that the Court require that THE DELANEY AT LAKE WACO prove its causes of action by a preponderance of the credible evidence or such higher standard as may be applicable.

AFFIRMATIVE DEFENSES / DENIALS

3.                  Windsor DENIES that any action or inaction of WINDSOR was a proximate or producing cause of damages to THE DELANEY AT LAKE WACO.

4.                  WINDSOR asserts the failure of THE DELANEY AT LAKE WACO to state a claim upon which relief may be granted

5.                  WINDSOR asserts the defense of justification.

6.                  WINDSOR asserts the defense of consent, effective consent and/or reasonable belief of consent.

7.                  WINDSOR denies that any of his actions were improper.

8.                  WINDSOR denies that any of his actions were extreme and outrageous.

9.                  WINDSOR specifically denies that his conduct made the basis of this lawsuit was negligent, malicious, or wrongful.

10.              WINDSOR asserts the defense of unclean hands.

11.              WINDSOR denies that he owes any common law, statutory or contractual duty to THE DELANEY AT LAKE WACO for which he could possibly be liable in damages.

12.              WINDSOR alleges fraud.

13.              WINDSOR alleges illegality.

14.              WINDSOR alleges contributory negligence.

15.              WINDSOR alleges perjury.

16.              WINDSOR alleges elder abuse.

17.              WINDSOR alleges preemption by federal law.

18.              WINDSOR alleges failure to mitigate damages.

19.              WINDSOR alleges attorneys’ fees award not permissible.

20.              WINDSOR alleges contrary to public policy.

21.              WINDSOR alleges restraint of trade.

22.              WINDSOR alleges Freedom of Speech and Freedom of Press.

23.              WINDSOR alleges Justification.

24.              WINDSOR alleges execution of public duty.

25.              WINDSOR alleges improper notice.

26.              WINDSOR alleges fair use.

27.              WINDSOR alleges truth.

28.              WINDSOR alleges statements are opinion.

29.              WINDSOR alleges statements are fair comment.

30.              WINDSOR alleges that the claim of violation of Chapter 42 of the Texas Penal Code is frivolous and outrageous.

31.              WINDSOR denies that he has committed violation of Chapter 42 of the Texas Penal Code.

32.              WINDSOR alleges that statements made in the Third-Party Petition are false.

33.              WINDSOR denies that he has committed libel.

34.              WINDSOR denies that he has committed business disparagement.

35.              WINDSOR denies that he has committed tortious interference with contract.

36.              WINDSOR alleges that the Affidavit of Scott Bushong is false and perjury.

37.              WINDSOR alleges that the purported Statutory Durable Power of Attorney for Michael Dutschmann is a fraud and is void.

38.              WINDSOR alleges that the purported Statutory Durable Power of Attorney for Doug Dutschmann is a fraud and is void.

39.              WINDSOR alleges that the purported Medical Power of Attorney for Michael Dutschmann is a fraud and is void.

40.              WINDSOR reserves the right to amend this Answer as may be authorized by the Court, and as may be permitted by the Texas Rules of Civil Procedure.

41.              WINDSOR reserves the right to assert an Anti-Slapp action against THE DELANEY AT LAKE WACO.

42.              WINDSOR references and incorporates herein his Third-Party Petition and Application for TRO.

WHEREFORE, PREMISES CONSIDERED, WINDSOR prays that THE DELANEY AT LAKE WACO take nothing by way of its suit against WINDSOR, and that WINDSOR be awarded taxable costs of Court and that the Court grant such other and further relief to which WINDSOR is justly entitled.

This 10th day of January, 2022,                                                                    

/s/ William M. Windsor_____________

William M. Windsor, Proudly Pro Se

100 East Oak Terrace Drive, Unit B3

Leesburg, Florida 34748

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DECLARATION

My name is William M. Windsor.  My date of birth is October 2, 1948.  My address is 100 East Oak Terrace Drive, Unit B3, Leesburg, Florida 34748, Lake County, USA.

I declare under penalty of perjury that the foregoing is true and correct based upon my personal knowledge.

Executed in Lake County, State of Florida, on the 10th day of January, 2022,

/s/ William M. Windsor_____________

William M. Windsor, Proudly Pro Se

100 East Oak Terrace Drive, Unit B3

Leesburg, Florida 34748

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WINDSOR’S Counterclaim to THE DELANEY AT LAKE WACO’s Third-Party Petition and Application for Temporary Restraining Order and Request for Temporary Injunction

WILLIAM WINDSOR (“THIRD-PARTY DEFENDANT” or “WINDSOR”) files this Counterclaim to THE DELANEY AT LAKE WACO’s Third-Party Petition and Application for Temporary Restraining Order and Request for Temporary Injunction, and alleges as follows:

DISCOVERY CONTROL PLAN

1.                  WINDSOR intends to conduct discovery under Level 2 of Texas Rule of Civil Procedure 190.3 and affirmatively pleads that this suit is not governed by the expedited-actions process in Texas Rule of Civil Procedure 169 because it seeks injunctive relief.

2.                  WINDSOR seeks monetary relief of $100,000 or more and nonmonetary relief.

VENUE AND JURISDICTION

1.                  THE DELANEY AT LAKE WACO is a Texas corporation.

2.                  Venue is proper in McLennan County under TEX. CIV. PRAC. & REM. CODE § 15.002.  A substantial part of the events giving rise to the claims occurred in McLennan County, Texas.

3.                  This court has jurisdiction on this matter pursuant to Texas Statutes.  This Court has personal jurisdiction over THE DELANEY AT LAKE WACO as an entity that regularly conducts business in McLennan County. 

4.                  Venue is proper in this Court on the grounds that some or all of the conduct at issue took place in McLennan County.

5.                  This Court has jurisdiction over this matter because the amount in controversy exceeds the minimum jurisdictional limits of this Court.



FACTS

6.                  The FLASH DRIVE filed by Marcie Schreck (“MARCIE”) contains evidence referenced herein.  The FLASH DRIVE is incorporated herein. 

7.                  Upon information and belief, no doctor has ever diagnosed Wanda Dutschmann (“GREAT-GRANDMA”) with Dementia or Alzheimer’s.

8.                  On 8/2/2019, Doug Dutschmann executed a Statutory Durable Power of Attorney. EXHIBIT 1 is invalid and was revoked.

9.                  On 10/15/2019, Michael Dutschmann executed a Statutory Durable Power of Attorney.  EXHIBIT 2 is invalid and was revoked.

10.              Michael Dutschmann does not have GREAT-GRANDMA’s Medical Power of Attorney.  EXHIBIT 10 is void and was revoked.

11.              Doug Dutschmann does not have GREAT-GRANDMA’s Medical Power of Attorney as none was ever signed, and if one was ever signed, it was revoked on 1/22/2021.

12.              Michael and Doug Dutschmann have lied to many people claiming they have valid powers of attorney for GREAT-GRANDMA.  They do not have Statutory Durable Powers of Attorney.  They do not have medical powers of attorney.

13.              WINDSOR is not an agent for Marcie Schreck (“MARCIE.”)  These claims in the Third-Party Petition are false.

14.              On 12/22/2021, GREAT-GRANDMA revoked her 2019 powers of attorney, as noted in the Third-Party Petition in Paragraph 13.  She had the absolute right to do so, and she had the capacity to do so. [EXHIBIT 12.]  Dozens of recorded telephone conversations between MARCIE, WINDSOR, and GREAT-GRANDMA demonstrate her competency.  In addition, there is nothing in the Texas Statutes that says a principal must be competent to revoke a Statutory Durable Power of Attorney.  Texas Health and Safety Code Sec. 166.155 says a principal does NOT have to be competent to revoke a Medical Power of Attorney.

15.              WINDSOR has never posted anything that was not factual or his opinion regarding THE DELANEY AT LAKE WACO.

16.              WINDSOR is a member of the press since 1965.  He is producing and directing a film exposing Life Care Services and THE DELANEY AT LAKE WACO.

17.              On December 22, 2021, MARCIE did not create a disturbance at THE DELANEY AT LAKE WACO.  EXHIBIT 53 is a recording of the entire “event.”  WINDSOR listened to the event by speakerphone.  The DELANEY AT LAKE WACO called the police to deny GREAT-GRANDMA the ability to execute her legal documents in front of a notary and witnesses.  The DELANEY AT LAKE WACO routinely makes false accusations to the police and commits perjury.

18.              GREAT-GRANDMA has no “power of attorney,” so Paragraphs 17 and 23 of the Third-Party Petition is false.

19.              On December 23, 2021, MARCIE Schreck did not threaten Paula Smith with legal action.  She filed a legal action.  Merriam-Webster defines “threat” as “a declaration of the intention to inflict harm, pain, or misery.”  MARCIE Schreck did no such thing.

20.              GREAT-GRANDMA has been unlawfully restrained at THE DELANEY AT LAKE WACO, and this violates Penal Code Chapter 20 titled “Kidnapping, Unlawful Restraint.”

21.              WINDSOR has never made a false accusation on Twitter.  He always states the facts as he believes them to be, or he expresses his opinions.

22.              WINDSOR’s Yelp review of THE DELANEY AT LAKE WACO are the facts as he believes them to be, or expressions of his opinions.

23.              WINDSOR’s articles on LawlessAmerica.com are the facts as he believes them to be, or expressions of his opinions.  The lawsuit filed by MARCIE Schreck is reproduced on LawlessAmerica.com without comment.  The website says “Documentary Films, Magazine, Radio, TV.  It and Facebook contain this statement on every article: “I, William M. Windsor, am not an attorney.  This website expresses my OPINIONS.   The comments of visitors or guest authors to the website are their opinions and do not, therefore, reflect my opinions.  Anyone mentioned by name in any article is welcome to file a response.   This website does not provide legal advice.  I do not give legal advice.  I do not practice law.   This website is to expose government corruption, law enforcement corruption, political corruption, and judicial corruption.   Whatever this website says about the law is presented in the context of how I or others perceive the applicability of the law to a set of circumstances if I (or some other author) was in the circumstances under the conditions discussed.  Despite my concerns about lawyers in general, I suggest that anyone with legal questions consult an attorney for an answer, particularly after reading anything on this website.  The law is a gray area at best.  Please read ourLegal Notice and Terms.”

24.              Neither MARCIE Schreck nor WINDSOR have ever faxed letters to THE DELANEY AT LAKE WACO to have GREAT-GRANDMA designate MARCIE Schreck as her Guardian.  All of these faxes are on he Flash Drive.  None of these communications to GREAT-GRANDMA were ever given to her.

25.              MARCIE Schreck and WINDSOR tried to get medical care for GREAT-GRANDMA long before Paragraph 21 of the Third-Party Petition claims.  The Flash Drive is filled with evidence.  GREAT-GRANDMA told MARCIE Schreck and WINDSOR repeatedly for weeks that she needed to go to the hospital.

26.              WINDSOR has never in his life identified himself as a lawyer.  Paragraph 22 of the Third-Party Petition is a lie.  A DAMN LIE.  This is typical of THE DELANEY AT LAKE WACO and their attorneys.

27.              WINDSOR has never harassed anyone or made threatening voice mails.

28.              The attorney for THE DELANEY AT LAKE WACO kept trying to stop WINDSOR from exercising free speech by claiming he had to contact her.  WINDSOR was not a party to the lawsuit and had no obligation to the attorney.

29.              GREAT-GRANDMA has not had a cell phone, so this is another falsehood in the Third-Party Petition, Paragraph 32.  GREAT-GRANDMA has told MARCIE Schreck and WINDSOR that her attempts to call 911 are blocked.  Paragraph 32 is false.  MARCIE Schreck and WINDSOR have dozens of recorded calls from GREAT-GRANDMA as to every issue reported.

30.              WINDSOR never sent harassing emails.  He sent emails attempting to get the dishonest people who are Defendants to take action and do the right thing.  Paragraph 33 is false.

31.              WINDSOR never called 911 and posed as an attorney as falsely and maliciously claimed in Paragraph 34 of the Third-Party Petition.  Upon information and belief, Krissy Matthews was not present as this was stated by GREAT-GRANDMA.

32.              WINDSOR is actively pursuing criminal charges against THE DELANEY AT LAKE WACO and other Defendants.  An investigation has begun with the McLennan County Criminal District Attorney’s Office.  The FBI will be next.

33.              THE DELANEY AT LAKE WACO did steal GREAT-GRANDMA’s mail, and it appears they have stolen additional mail on January 10, 2022.

34.              Paragraph 36 of the Third-Party Petition is a lie and an outrage.  EXHIBIT E to the Third-Party Petition is an Affidavit dated 1/4/2022 that makes only three statements of purported facts.  Scott Bushong (“BUSHONG”) fails to identify who purportedly made such statements, where, or when.  Scott BUSHONG could not possibly have personal knowledge of whether a “resident” had been kidnapped, any “resident had been denied emergency services, or whether The Delaney at Lake Waco had stolen any resident’s mail.  Scott BUSHONG has committed perjury in his Affidavit.

35.              Paragraph 37 of the Third-Party Petition is a lie and an outrage.  WINDSOR has been publishing since 1977, and he has never been accused of libel.  WINDSOR has not published false statements of fact or defamatory statements about THE DELANEY AT LAKE WACO.

36.              Paragraph 38 of the Third-Party Petition is a lie and an outrage.  WINDSOR has not posted false statements of fact or defamatory statements about THE DELANEY AT LAKE WACO.

37.              Paragraph 39 of the Third-Party Petition is a lie and an outrage.  WINDSOR has not posted false statements of fact or defamatory statements about THE DELANEY AT LAKE WACO.  WINDSOR’s complaints to the Waco Police Department have been factual and are not grounds for a claim of tortious interference.  Neither WINDSOR nor MARCIE Schreck are aware of any contract between GREAT-GRANDMA and THE DELANEY AT LAKE WACO.  All requests for any documents have been ignored. 

38.              MARCIE has never posted false statements about THE DELANEY AT LAKE WACO.

39.              Paragraph 40 of the Third-Party Petition is ridiculous.  Chapter 42 of the Texas Penal Code is EXHIBIT 339.

40.        WINDSOR has not violated Texas Penal Code Section 42.01.  WINDSOR has not committed DISORDERLY CONDUCT.

41.        WINDSOR has not intentionally or knowingly used abusive, indecent, profane, or vulgar language in a public place, and the language by its very utterance tended to incite an immediate breach of the peace.  WINDSOR has not made an offensive gesture or display in a public place, and WINDSOR has not made an offensive gesture or display in a public place tending to incite an immediate breach of the peace.  WINDSOR has not created, by chemical means, a noxious and unreasonable odor in a public place.

42.        WINDSOR has not abused or threatened a person in a public place in an obviously offensive manner; WINDSOR has not made unreasonable noise in a public place other than a sport shooting range, as defined by Section 250.001, Local Government Code, or in or near a private residence that he has no right to occupy; WINDSOR has not had fights with another in a public place; WINDSOR has not discharged a firearm in a public place other than a public road or a sport shooting range, as defined by Section 250.001, Local Government Code; WINDSOR has not displayed a firearm or other deadly weapon in a public place in a manner calculated to alarm; WINDSOR has not discharged a firearm on or across a public road.

43.        WINDSOR has not exposed his anus or genitals in a public place and is not reckless about whether another may be present who will be offended or alarmed by his act; WINDSOR has not done anything for a lewd or unlawful purpose; WINDSOR has not entered on the property of another and looked into a dwelling on the property through any window or other opening in the dwelling; WINDSOR has not while on the premises of a hotel or comparable establishment, looked into a guest room not the person’s own through a window or other opening in the room; WINDSOR has not while on the premises of a public place, looked into an area such as a restroom or shower stall or changing or dressing room that is designed to provide privacy to a person using the area.

44.              Paragraphs 41, 42, and 43 list ALL of the statutory provisions required to establish “disorderly conduct.”  WINDSOR has done none of these. 

45.              WINDSOR lives in Florida, has not left the state for four years, has never been to THE DELANEY AT LAKE WACO, and hasn’t been to Waco in at least 7 years.  These criminal acts would be impossible to do from Florida.  This is malicious prosecution to the max.

46.              WINDSOR is 73-years-old, disabled, lives alone.  For the last 13 years, he has spent his time helping victims of abuse and INjustice.  He loves helping people.  He hates liars, dishonest people, and anyone who abuses animals, children, disabled, and the elderly.    

47.              Four months ago, after WINDSOR helped a victim of corruption in Ellis County Texas (John Eric Armstrong) get his bogus charge dismissed and get released from over a year of solitary confinement, Marcie Schreck (“MARCIE”) reached out to WINDSOR on Facebook.  WINDSOR has over 50,000 followers on his Facebook pages, 11,000 on LinkedIn, and he has met face-to-face with over 2,000 victims of various forms of Injustice during a 50-state trip to produce and direct a documentary about government, judicial law enforcement, and attorney corruption.  It was presented to the United States Congress in February 2013.

48.              WINDSOR has seen all types of wrongdoing, including elder abuse.  “Isolate, medicate, and steal the estate.”  That’s usually the game played by the crooked people.  In Wanda Dutschmann’s case, WINDSOR is not sure about the medicate part yet, but it’s his opinion that it appears we have isolate and steal the estate in the instant case.

49.              WINDSOR has announced that he will produce and direct a documentary film about elder abuse.  It will be centered in Waco, Texas and will be the story of claims of wrongdoing by THE DELANEY AT LAKE WACO and its many parent companies, including Life Care Companies and Life Care Services.  Upon information and belief, there is significant wrongdoing being perpetrated by THE DELANEY AT LAKE WACO and its many parent companies.

50.              WINDSOR evaluates the people and the cases when he is asked to help.  He has 754 people in a queue seeking help as he types this.  WINDSOR will only help people who he has determined are absolutely honest.  MARCIE Schreck is absolutely honest.  He has spoken with her hundreds of times, and he has received over 12,000 documents relating to her Autistic son’s case (Hunter Tyler Schreck) and Wanda Dutschmann’s situation/case.

51.              WINDSOR has spoken to Wanda Dutschmann (“GREAT-GRANDMA “) several times, and he has listened to at least 70 audio recordings of her conversations with Marcie Schreck between October 2021 and 1/10/2022.

52.              WINDSOR is not a doctor, but he’s never heard anything said or not said by GREAT-GRANDMA to indicate she has dementia.  WINDSOR almost fell out of his chair when GREAT-GRANDMA corrected Marcie about the number of days in November.  When GREAT-GRANDMA does miss something, WINDSOR suspects it’s because she can’t hear.  Her ears are horribly impacted with wax.  She has never had the use of her hearing aids on the 70 calls WINDSOR has listened to.  Stick your index finger in each of your ears; say something; that’s probably what GREAT-GRANDMA can hear.

53.              One of the first things WINDSOR did as he began looking at GREAT-GRANDMA’s situation was to Google the place where she is living – The Delaney at Lake Waco.  WOW!  Really nice-looking place, he thought.  WRONG.  It’s a horrible place.  EXHIBIT 201 is GREAT-GRANDMA’s bed.  TheDelaneyatLakeWaco.com presents a totally different picture.

54.              GREAT-GRANDMA has been begging to go to the hospital.  MARCIE and WINDSOR have tried everything to get her there. [EXHIBITS 84, 85, 125, 178, 185, 186.]  EXHIBITS 210, 235, and 340 are new recordings in the Dropbox.

55.              WINDSOR has been aware for months that GREAT-GRANDMA has medical issues that needed to be addressed, and it was clear to him from recordings that The Delaney at Lake Waco was not doing anything.

56.              On 12/18/2021, MARCIE Schreck drove from Amarillo to The Delaney at Lake Waco and saw her MOM. [EXHIBIT 41.]  GREAT-GRANDMA didn’t want MARCIE to leave. [EXHIBIT 43.]

57.              On 12/21/2021, WINDSOR contacted Alyssa CLARIDY and Scott BUSHONG of The Delaney.  They refused to wheel GREAT-GRANDMA to the front door where two witnesses and a notary were arranged to do their jobs.  Scott BUSHONG refused to transport GREAT-GRANDMA to the front door or front porch.  The people who had been hired by MARCIE Schreck and WINDSOR were sent home.

58.              On 12/21/2021, Marcie Schreck and WINDSOR coordinated a notary and paid witnesses to go to The Delaney AT LAKE WACO to get GREAT-GRANDMA’s Statutory Durable Power of Attorney, Medical Power of Attorney, and Last Will and Testament notarized and witnessed.  She hasn’t had a driver’s license in 30 years, and the notary would not accept other forms of identification. [EXHIBIT 45.]  The effort failed.  If the notary had signed, GREAT-GRANDMA could have immediately been taken to the hospital.  WINDSOR found the notary, so he was involved in all of this.

59.              On 12/21/2021, Marcie Schreck reported elder abuse to several agencies, including Adult Protective Services. [EXHIBIT 48.] [EXHIBIT 50.]

60.              On 12/22/2021, WINDSOR notified Michael Dutschmann by telephone that his power-of-attorney had been terminated by GREAT-GRANDMA.

61.                  On 12/23/2021, Marcie Schreck tried to file a motion for a TRO, but the Clerk’s office was closed, and there was no judge available.

62.                  On 12/23/2021, Marcie Schreck and WINDSOR coordinated the notary, two paid witnesses from Bullet courier service, a 79-year-old friend of GREAT-GRANDMA’s, Betty Elliott, and Hunter Tyler Schreck, grandson of WANDA DUTSCHMANN.  EXHIBIT 53 is the recording of the hour-and-a-half at The Delaney AT LAKE WACO.  WINDSOR was on the phone during the ordeal.  The Delaney AT LAKE WACO did not bring GREAT-GRANDMA down to sign.  I sent the paid witnesses home.  Then The Delaney AT LAKE WACO claimed they were bringing her out, so WINDOR called and paid more for the couriers to return.  The notary came back as well.  No GREAT-GRANDMA.  WINDSOR told Marcie to call 911, but The Delaney AT LAKE WACO had already done so.  Marcie Schreck and Betty were detained by the police; their driver’s licenses were seized; and they were told they were being charged with criminal trespassing.  WINDSOR told the police they were violating the law and the U.S. and Texas constitutions. They backed off and said if they didn’t leave, they would charge them with disturbing the peace.  The officers claimed GREAT-GRANDMA was fine, but they admitted on tape that nothing was said or done about her ears or bowels.

63.                  On 12/23/2021, Marcie Schreck went to the Waco Police Department to file a criminal complaint against The Delaney AT LAKE WACO.  She saw Officer Law.  WINDSOR was listening in.  Great-GRANDMA told Officer Law that she wanted to go to the hospital.  He said there was nothing the police would do.  WINDSOR told him he was risking her life. [EXHIBIT 57.] [EXHIBIT 60.]

64.                  On 12/23/2021, Marcie Schreck sent WINDSOR a recording of a call to The Delaney when Alma MORROW told her she would not transfer any calls to Wanda Dutschmann.  She told Marcie Schreck to talk to her brothers and sister. [EXHIBIT 55.] 

65.                  On 12/23/2021, Marcie Schreck sent WINDSOR a recording of a call to The Delaney AT LAKE WACO when Paula Smith told her she was not allowed to see GREAT-GRANDMA, and if she tried, the authorities would be called. [EXHIBIT 56.]

66.                  Since 12/24/2021, neither Marcie Schreck nor WINDSOR have been allowed to call The Delaney AT LAKE WACO.  They intercept their calls and route them to a continual ringing.  WINDSOR let the phone ring for five hours one evening.

67.                  On 12/25/2021, WINDSOR sent an email to the attorney for LCC and included the Petition filed on 12/23/2021. [EXHIBIT 17.]

68.                  On 12/25/2021 at 9:11 p.m., WINSOR sent a fax for Marcie Schreck to GREAT-GRANDMA at The Delaney AT LAKE WACO. [EXHIBIT 18.]  The Fax Confirmation shows it was successfully transmitted.

69.                  On 12/25/2021 at 10:12 p.m., WINDSOR sent a fax for Marcie Schreck to GREAT-GRANDMA at The Delaney AT LAKE WACO. [EXHIBIT 19.]  The Fax Confirmation shows it was successfully transmitted.

70.              On 12/26/2021, Marcie Schreck filed the original Petition and Complaint in this case. [EXHIBIT 195.]

71.              On 12/26/2021, WINDSOR called The Delaney AT LAKE WACO several times attempting to reach GREAT-GRANDMA.  His calls rang forever without an answer.  The last attempt rang for 28 minutes.

72.              On 12/26/2021, WINDSOR sent a fax to ALMA MORROW of The Delaney AT LAKE WACO. [EXHIBIT 21.]

73.              On 12/26/2021, WINDSOR sent a fax to Joel D. NELSON of LCC. [EXHIBIT 22.]

74.              On 12/26/2021, WINDSOR sent a fax to Bridgette Uhlemann of LCC. [EXHIBIT 23.]

75.              On 12/27/2021, Marcie Schreck left detailed voice mails for Doug Dutschmann, Jill Perryman, and Krissy Matthews. [EXHIBITS 86, 87, 88, 89, 90, 91.]

76.              On 12/27/2021, Marcie Schreck spoke with Michael Dutschmann, and what WINDSOR heard was that he admitted there was no dementia diagnosis for GREAT-GRANDMA at The Delaney AT LAKE WACO. [EXHIBIT 98.]

77.              On 12/27/2021, WINDSOR sent a fax to The Delaney AT LAKE WACO.  It said: “Please take Wanda Dutschmann in Room 1004 to Baylor Scott & White immediately.”  The fax was successfully transmitted.  No one ever did what was asked, and no one ever responded. [EXHIBIT 212.]

78.              On 12/27/2021, WINDSOR sent an email to Scott Bushong, Paula Smith, and The Delaney AT LAKE WACO titled “Wanda Dutschmann Payment Information.  It included Notice of January 5 Hearing; Withdrawal of the Powers of Attorney to Michael and Doug Dutschmann; Petition and Exhibits; Medical Power of Attorney; new Statutory Durable Power of Attorney; and GREAT-GRANDMA’s Last Will and Testament. [EXHIBIT 211.]   There was no response.

79.              On 12/27/2021, WINDSOR sent a fax to Life Care Companies and Joel Nelson.  It said: “Please take Wanda Dutschmann in Room 1004 to Baylor Scott & White immediately.”  The fax was successfully transmitted.  No one ever did what was asked, and no one ever responded. [EXHIBIT 213.]

80.              On 12/27/2021, WINDSOR sent a fax to the Waco Police Department.  It said: “Please take Wanda Dutschmann in Room 1004 to Baylor Scott & White immediately.”  The fax was successfully transmitted.  No one ever did what was asked, and no one ever responded. [EXHIBIT 214.]

81.              On 12/27/2021, WINDSOR sent a fax to American Medical Response Ambulance (“AMR”).  It said: “Please take Wanda Dutschmann in Room 1004 to Baylor Scott & White immediately.”  The fax was successfully transmitted.  No one ever did what was asked, and no one ever responded. [EXHIBIT 215.]

82.              On 12/27/2021, WINDSOR sent a fax to Mayor Dillon Meek - City of Waco.  It said: “Please take Wanda Dutschmann in Room 1004 to Baylor Scott & White immediately.”  The fax was successfully transmitted.  No one ever did what was asked, and no one ever responded. [EXHIBIT 216.]

83.              On 12/27/2021, WINDSOR sent a fax to Dr. David Fedro.  It said: “Please take Wanda Dutschmann in Room 1004 to Baylor Scott & White immediately.”  The fax was successfully transmitted.  No one ever did what was asked, and no one ever responded. [EXHIBIT 217.]

84.              On 12/27/2021, WINDSOR sent a fax to Dr. David Fedro.  It said: “Please take Wanda Dutschmann in Room 1004 to Baylor Scott & White immediately.”  The fax was successfully transmitted.  No one ever did what was asked, and no one ever responded. [EXHIBIT 218.]

85.              On 12/27/2021, WINDSOR sent a fax to Barbara Weir.  It said: “Please take Wanda Dutschmann in Room 1004 to Baylor Scott & White immediately.”  The fax was successfully transmitted.  No one ever did what was asked, and no one ever responded. [EXHIBIT 219.]

86.              On 12/27/2021, WINDSOR sent a fax to Barbara Weir.  It said: “Please take Wanda Dutschmann in Room 1004 to Baylor Scott & White immediately.”  The fax was successfully transmitted.  No one ever did what was asked, and no one ever responded. [EXHIBIT 220.]

87.              On 12/27/2021, WINDSOR sent a fax to AMR.  It said: “Please take Wanda Dutschmann in Room 1004 to Baylor Scott & White immediately.”  The fax was successfully transmitted.  No one ever did what was asked, and no one ever responded. [EXHIBIT 221.]

88.              On 12/28/2021, WINDSOR sent a fax to Susan Briones, purported attorney for The Delaney AT LAKE WACO and others in that line of business.  Susan Briones ignored much of this. [EXHIBIT 222.]  It sent her a copy of Wanda Dutschmann’s withdrawal of powers of attorney to Michael and Doug Dutschmann.  Susan Briones acknowledged receipt of this email in her email to WINDSOR on 12/28/2021. [EXHIBIT 223.]  Yet on 1/3/2022, Susan Briones filed a copy of that void power of attorney with this Court claiming falsely and maliciously it was in effect. [EXHIBIT 291.]

89.              On 12/29/2021, WINDSOR sent an email to Susan Briones with the Withdrawal of the powers of attorney for Michael Dutschmann and Doug Dutschmann. [EXHIBIT 140.]

90.              On 12/30/2021, Marcie Schreck sent a Federal Express package to Wanda Dutschmann at The Delaney AT LAKE WACO.  It included a cover letter in an envelope addressed to Wanda Dutschmann.  It included a stamped envelope to Michael Dutschmann containing a letter Wanda Dutschmann was to sign and mail to him.  It also included a stamped envelope to The Delaney AT LAKE WACO containing a letter Wanda Dutschmann was to sign and mail to The Delaney AT LAKE WACO.  It also contained an additional copy of the letters to Michael Dutschmann and The Delaney AT LAKE WACO for Wanda to sign and give to Marcie Schreck. [EXHIBIT 226.]  EXHIBIT 227 is the receipt. 

91.              On 12/31/2021, the Federal Express package was delivered. [EXHIBIT 228.]

92.              On 1/2/2022 at approximately 12:01 p.m., WINDSOR played a recording for the LCS voice mail from GREAT-GRANDMA.  GREAT-GRANDMA made it very clear that she had revoked all powers of attorney for Michael Dutschmann and Doug Dutschmann.

93.              On 1/2/2022 at approximately 12:03 p.m., WINDSOR played a recording from GREAT-GRANDMA for the voice mail of attorney Susan Briones.  GREAT-GRANDMA made it very clear that she had revoked all powers of attorney for Michael Dutschmann and Doug Dutschmann.

94.              On 1/2/2022 at approximately 12:11 p.m., WINDSOR played a recording from GREAT-GRANDMA for Jill Perryman.  Her mother, GREAT-GRANDMA, made it very clear that she had revoked all powers of attorney for Michael Dutschmann and Doug Dutschmann.

95.              On 1/2/2022 at approximately 12:12 p.m., WINDSOR played a recording from GREAT-GRANDMA for Krissy Matthews.  Her mother, GREAT-GRANDMA, made it very clear that she had revoked all powers of attorney for Michael Dutschmann and Doug Dutschmann.

96.              On 1/2/2022 at approximately 12:01 p.m., WINDSOR played a recording for the LCS voice mail from GREAT-GRANDMA.  GREAT-GRANDMA made it very clear that she had revoked all powers of attorney for Michael Dutschmann and Doug Dutschmann. 

97.              On 1/2/2022 at approximately 1:58 p.m., WINDSOR played a recording from GREAT-GRANDMA for the voice mail of attorney Susan Briones.  GREAT-GRANDMA made it very clear that she had revoked all powers of attorney for Michael Dutschmann and Doug Dutschmann.

98.              On 1/2/2022 at approximately 2:04 p.m., WINDSOR played a recording from GREAT-GRANDMA for the voice mail of Joel Nelson, CEO of LCC.  GREAT-GRANDMA made it very clear that she had revoked all powers of attorney for Michael Dutschmann and Doug Dutschmann.

99.              On 1/2/2022 at approximately 2:07 p.m., WINDSOR played a recording from GREAT-GRANDMA for the voice mail of Bridgette Uhlemann, in-house counsel for LCC and registered agent for LCS Waco Operations, owner of The Delaney AT LAKE WACO.  GREAT-GRANDMA made it very clear that she had revoked all powers of attorney for Michael Dutschmann and Doug Dutschmann.

100.              On 1/2/2022 at approximately 4:33 p.m., WINDSOR played a recording for the voice mail of Scott Bushong from GREAT-GRANDMA.  WINDSOR conveyed that GREAT-GRANDMA is being unlawfully restrained.  Scott Bushong never returned WINDSOR’s call.

101.              On 1/2/2022 at approximately 4:38 p.m., WINDSOR tried to play GREAT-GRANDMA’s recording to The Delaney AT LAKE WACO, but his call was blocked. 

102.              On 1/2/2022 at approximately 4:43 p.m., WINDSOR played a recording for Barbara Weir’s voice mail from GREAT-GRANDMA.  Barbara Weir never returned WINDSOR’s call.

103.              On 1/2/2022 at approximately 4:50 p.m., WINDSOR called American Medical Response, the ambulance service for the City of Waco.  He had called before with no help at all.  But on the 2nd, he reached KayKay.  She was as sweet as could be.  She listened patiently and was shocked by what was going on at The Delaney AT LAKE WACO.  She said she would dispatch an ambulance and call the police to send someone out for a welfare check on Wanda Dutschmann.

104.              Kay-Kay reported that the ambulance was there, but there was a delay.  WINDSOR was pretty sure HE knew what that meant – liars from The Delaney AT LAKE WACO denying GREAT-GRANDMA her medical right to go to the hospital.

105.              GREAT-GRANDMA called Marcie Schreck and WINDSOR a little later on 1/2/2022 to say: “…the police came, but they didn’t save me.”  “They had the the the thing that you lay down on, whatever you call it, but they took it with them.”  GREAT-GRANDMA felt like she was inches from freedom.  But she was heartbroken when she reported that someone from The Delaney AT LAKE WACO spoke to the ambulance people and the officers, and they took the stretcher but left her behind.  We have an audio recording of this, but it was received too late to make the Flash Drive of evidence filed so far.  The first 2:11 of EXHIBIT 210 in the dropbox tells the important part of the story. 

106.              On 1/2/2022 at 9:43 pm., WINDSOR sent an email to Defendants. [EXHIBIT 225.]  He attached the audio recording of GREAT-GRANDMA saying Dr. David Fedro had not examined her.  GREAT-GRANDMA was never seen by Dr. David Fedro or any doctor. [EXHIBIT 133.]  Upon information and belief, someone impersonated Dr. David Fedro to the police.  If it wasn’t for this impersonator, GREAT-GRANDMA would have made it to the hospital, and her documents would have been witnessed and notarized there.  WINDSOR reported criminal complaints against The Delaney AT LAKE WACO.  A demand was made on Michael Dutschmann or financial information.

107.              On 1/2/2022 at 11:20 pm., WINDSOR sent an email to Defendants.  He attached the audio recording of Sergeant Aaron Mitzel of the Waco Police Department saying he spoke with Defendant Dr. David Fedro who told him he evaluated Wanda Dutschmann that day and there was no reason to go to the ER. [EXHIBIT 224.]  GREAT-GRANDMA was never seen by Dr. David Fedro or any doctor. [EXHIBIT 133.]  Upon information and belief, someone impersonated Dr. David Fedro to the police.  If it wasn’t for this impersonator, GREAT-GRANDMA would have made it to the hospital, and her documents would have been witnessed and notarized there.

108.              On the evening of 1/3/2022, GREAT-GRANDMA called to report that her mail had been “intercepted.”  GREAT-GRANDMA wheeled herself down to an area where there can sometimes be snacks.  She was expecting mail from Marcie, so when she saw several envelopes addressed to residents laying on the counter, she looked at the addresses to see if any were for her.  Hidden under the stack, she found an envelope without a stamp on it that was addressed to her.

109.              On 1/4/2022, Marcie Schreck sent an email to Defendants saying: “My Federal Express shipment to my mother, Wanda Dutschmann, was taken by someone with The Delaney AT LAKE WACO.  I demand it be immediately returned by delivering it to my mother and calling me on the phone so I can speak with her while one of the Delaney Defendants is present.  Mom will sign the letter to The Delaney AT LAKE WACO and hand it to the Delaney Defendant.  She will also sign the letter to Michael Dutschmann, and The Delaney must have it delivered to him personally before the hearing on Wednesday.”  M. Margaret signed for it on 12/31.  One or more people opened GREAT-GRANDMA’s package, hid a letter to her, and took two stamped letters that were in her FedEx envelope.  This is conversion as well as theft. [EXHIBIT 231.]

110.              On 1/3/2022, WINDSOR called Scott Bushong and left this demand from Marcie Schreck for him.

111.              On 1/3/2022, Marcie Schreck sent an email to Defendants demanding return of her stolen FedEx shipment. [EXHIBIT 230.]

112.              On 1/4/2022, WINDSOR sent an email to Defendants about the burglary at The Delaney AT LAKE WACO and the many crimes he believes have been in this case. [EXHIBIT 229.]

113.              WINDSOR has read the statutes regarding Statutory Durable Power of Attorney, and it expires when revoked.  There are no ifs, ands, or buts.  WINDSOR has reviewed every case in the history of Texas in Fastcase, and there is no case to dispute the clear terms of the statute.  WINDSOR doesn’t believe Michael Dutschmann’s Statutory Durable Power of Attorney was ever valid.  WINDSOR believes the signatures are forged and the notary is falsified.  GREAT-GRANDMA reports she never signed any such document before a notary.  And there is more….

114.              WINDSOR has read the statutes regarding Medical Power of Attorney, and MARCIE Schreck and WINDSOR have been unable to obtain any evidence that it was ever activated.  There is no certification in writing that GREAT-GRANDMA is unable to make her own healthcare decisions.  Furthermore, GREAT-GRANDMA revoked it, as the statute allows.  The Texas Health and Safety Code provides that treatment may not be withheld if GREAT-GRANDMA objects.  She has repeatedly objected to being denied examination by a doctor at a hospital.  In WINDSOR’s opinion, The Delaney AT LAKE WACO has violated Section 166.152.  Furthermore, WINDSOR believes the signature was forged.  The Medical Power of Attorney requires two signatures, and the signature of a family member is not allowed.  There was only one purported witness, son DOUG Dutschmann, so the Medical Power of Attorney was never valid.  And there is more….

CAUSES OF ACTION

CAUSE OF ACTION I -- Defamation – Libel

115.              WINDSOR incorporates and re-alleges paragraphs 1- 114 as if fully set forth at length herein.  THE DELANEY AT LAKE WACO has waged war on MARCIE Schreck and WINDSOR by making false statements of fact about MARCIE Schreck and WINDSOR, private individuals.   The statements made by THE DELANEY AT LAKE WACO were false and defamatory. The statements were made in reference to MARCIE Schreck and WINDSOR.  

116.              The disparaging statements either named MARCIE Schreck or WINDSOR or were of and concerning MARCIE Schreck or WINDSOR.

117.              Statements that THE DELANEY AT LAKE WACO has published about MARCIE Schreck or WINDSOR were communicated to third persons.

118.              As a direct and proximate cause of the defamatory publications, WINDSOR’s reputation was damaged.  Statements made by THE DELANEY AT LAKE WACO have harmed the reputation of WINDSOR, have lowered him in the estimation of the community, and have deterred third persons from associating or dealing with him.    

119.              Some statements made by THE DELANEY AT LAKE WACO impute the commission of crimes.  Some statements linking WINDSOR to crimes with no basis in fact demonstrate actual malice.

120.              Many statements made by THE DELANEY AT LAKE WACO impute fraud, misconduct, or incompetence in WINDSOR’s business, profession, or occupation.  Statements ascribed a lack of necessary skills that are specific and/or unique to the profession of being a producer and director of films or television shows.  These statements constitute defamation per se.

121.              Statements have been made unambiguously accusing WINDSOR of committing crimes.  These statements constitute defamation per se. 

122.              THE DELANEY AT LAKE WACO owed a duty to WINDSOR not to make defamatory and/or false statement.  That duty was violated and such violation of the duty was a proximate cause of damages to WINDSOR as described herein. Accordingly, WINDSOR states THE DELANEY AT LAKE WACO was negligent in its actions in publishing false and defamatory statements regarding WINDSOR and/or acted with malice or reckless disregard regarding the truth of their statements, and such breach of duty was a proximate cause of damages complained of by WINDSOR in this case.  WINDSOR is a private individual.

123.              WINDSOR issued cease and desist notices, and these will be ignored by THE DELANEY AT LAKE WACO.  This shows that THE DELANEY AT LAKE WACO acted with malice or reckless disregard regarding the truth of their statements. 

124.              THE DELANEY AT LAKE WACO was acting with actual malice and/or negligence when making the defamatory statements.  WINDSOR has suffered damages as a result of the defamatory statements published by THE DELANEY AT LAKE WACO.

125.              Correct and make a retraction of all of the false and/or defamatory information published or made within 30 days.  If you don’t have absolute proof that your published statements are true, then issue a correction and retraction.  The correction and retraction must include the following: (1) Give your legal name, address, and contact information. (2) List each false and/or defamatory statement with a specific statement that it is false and a retraction.  (3) Publish this on THE DELANEY AT LAKE WACO website.  (4) Email This email address is being protected from spambots. You need JavaScript enabled to view it. with the links to each and every published correction and retraction; put this in all caps in the subject line: CORRECTION AND RETRACTION.


CAUSE OF ACTION II – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

126.              WINDSOR incorporates and re-alleges paragraphs 11- 114 as if fully set forth at length herein.

127.              THE DELANEY AT LAKE WACO inflicted emotional distress on WINDSOR.  THE DELANEY AT LAKE WACO acted intentionally or recklessly. 

128.              Conduct of THE DELANEY AT LAKE WACO has been extreme and outrageous.  The things THE DELANEY AT LAKE WACO has done would prompt an average member of the community to exclaim “outrageous!” 

129.              The activities of THE DELANEY AT LAKE WACO have been so extreme that it has gone well beyond all possible bounds of decency, and it must be regarded as atrocious and utterly intolerable in a civilized society.  All of the acts of THE DELANEY AT LAKE WACO taken together amount to the type of extreme conduct that qualifies as intentional infliction of emotional distress.

130.              The conduct of THE DELANEY AT LAKE WACO caused the distress.

131.              The distress caused was severe emotional distress to WINDSOR. 

132.              There are no alternative causes of action that would provide a remedy for the severe emotional distress caused by the conduct of THE DELANEY AT LAKE WACO.

CAUSE OF ACTION III – TORTIOUS INTERFERENCE WITH PROSPECTIVE CONTRACTUAL RELATIONS

133.              WINDSOR incorporates and re-alleges paragraphs 1- 114 as if fully set forth at length herein.

134.              THE DELANEY AT LAKE WACO has interfered with the prospective contracts between GREAT-GRANDMA and WINDSOR. [EXHIBIT 9.]  THE DELANEY AT LAKE WACO has interfered with the STATUTORY DURABLE POWER OF ATTORNEY.

135.              There is an absolute probability that WINDSOR would have entered into a business relationship because GREAT-GRANDMA has already signed the STATUTORY DURABLE POWER OF ATTORNEY. [EXHIBIT 9.]

136.               Independently tortious or unlawful acts by THE DELANEY AT LAKE WACO prevented the relationship from occurring.  These have been detailed in the STATEMENT OF FACTS above.  THE DELANEY AT LAKE WACO HAS taken almost incomprehensible efforts to block WINDSOR from obtaining the signatures of a notary and witnesses on the contracts. [EXHIBITS 9, 10, 11.]

137.              THE DELANEY AT LAKE WACO did such acts with a conscious desire to prevent the relationship from occurring or THE DELANEY AT LAKE WACO knew the interference was certain or substantially certain to occur as a result of the conduct.

138.              windsor suffered actual harm or damages as a result of the interference of THE DELANEY AT LAKE WACO.  WINDSOR has been denied the right to act for and protect GREAT-GRANDMAWINDSOR has been denied the right to enforce GREAT-GRANDMA’s medical choices.  windsor has been sued for helping GREAT-GRANDMA, which harmed him.


CAUSE OF ACTION IV -- Business Disparagement

139.              WINDSOR incorporates and re-alleges paragraphs 1- 114 as if fully set forth at length herein.

140.              THE DELANEY AT LAKE WACO has waged war on MARCIE Schreck and WINDSOR by making false statements of fact about MARCIE Schreck and WINDSOR.   The statements made by THE DELANEY AT LAKE WACO were false and defamatory.  The statements were made in reference to MARCIE Schreck and WINDSOR.  THE DELANEY AT LAKE WACO was acting with actual malice and/or negligence when making the defamatory statements.  

141.              WINDSOR has helped thousands of people with problems of INjustice for the last 14 years.   He has filmed over 2,000 stories and produced and directed a documentary that was distributed to every member of the U.S. House and Senate in 2013.  The disparagement of WINDSOR and LAWLESS AMERICA has damaged the reputation of his business.

142.              WINDSOR has suffered damages as a result of the business disparagement of THE DELANEY AT LAKE WACO.


CAUSE OF ACTION V --
MALICIOUS PROSECUTION


143.              WINDSOR incorporates and re-alleges paragraphs 1- 114 as if fully set forth at length herein.

144.              WINDSOR will prove that the original case was terminated in his favorthat THE DELANEY AT LAKE WACO played an active role in the original case, that THE DELANEY AT LAKE WACO did not have probable cause or reasonable grounds to support the original case, and that THE DELANEY AT LAKE WACO pursued the case with an improper purpose.

145.              WINDSOR has suffered damages as a result of the malicious prosecution of THE DELANEY AT LAKE WACO.


APPLICATION FOR TEMPORARY RESTRAINING ORDER

146.              WINDSOR respectfully requests that this Court enter a temporary restraining order restraining THE DELANEY AT LAKE WACO from interfering in any manner with WINDSOR’s work as a writer, producer, and director.

147.              WINDSOR respectfully requests that this Court enter a temporary restraining order restraining THE DELANEY AT LAKE WACO from making false statements orally or in writing regarding WINDSOR.

148.              WINDSOR further requests that THE DELANEY AT LAKE WACO cease doing anything that interferes with WINDSOR’s business ventures.

149.              WINDSOR further requests that THE DELANEY AT LAKE WACO cease doing anything that interferes with WINDSOR’s efforts to help victims of INjustice.

150.              It is probable that WINDSOR will recover from THE DELANEY AT LAKE WACO after a trial on the merits because of the nature of the defamation is presumed.

151.              If WINDSOR’s application is not granted, harm is imminent because THE DELANEY AT LAKE WACO has proven that they will stop at nothing to damage him and block him from doing his job.

152.              The harm that will result if the temporary restraining order is not issued is irreparable because WINDSOR’s business reputation is being damaged by THE DELANEY AT LAKE WACO’s false statements regarding WINDSOR.  WINDSOR has no adequate remedy at law because THE DELANEY AT LAKE WACO has charged him with criminal behavior with absolutely no legal basis to do so.  Moreover, the damages are incalculable and WINDSOR has no realistic way to ascertain the number of prospective customers who may view or hear such information and decide not to do business with WINDSOR.

REQUEST FOR TEMPORARY INJUNCTION

153.              WINDSOR asks this Court to set his application for temporary injunction for a hearing and, after the hearing, issue a temporary injunction against THE DELANEY AT LAKE WACO.


REQUEST FOR PERMANENT INJUNCTION

154.              WINDSOR asks the Court to set his request for a permanent injunction for a full trial on the merits and, after the trial, issue a permanent injunction against THE DELANEY AT LAKE WACO as described herein.

155.              WINDSOR demands a jury trial.

156.              All conditions precedent to WINDSOR’s claims for relief have been performed or have occurred.

WHEREFORE, PREMISES CONSIDERED, William Windsor respectfully requests that THE DELANEY AT LAKE WACO be cited to appear and answer and that WINDSOR be awarded the following relief against THE DELANEY AT LAKE WACO:

a. Temporary restraining order;

b. Temporary injunction;

c. Permanent injunction;

d. Actual damages;

e. Prejudgment and post-judgment interest;

f. Court costs

g. All other relief to which WINDSOR is justly entitled.


Respectfully submitted,

This 11th day of January, 2022,                                                                    

/s/ William M. Windsor_____________

William M. Windsor, Proudly Pro Se
100 East Oak Terrace Drive, Unit B3
Leesburg, Florida 34748
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DECLARATION

My name is William M. Windsor.  My date of birth is October 2, 1948.  My address is 100 East Oak Terrace Drive, Unit B3, Leesburg, Florida 34748, Lake County, USA.

I declare under penalty of perjury that the foregoing is true and correct based upon my personal knowledge.

Executed in Lake County, State of Florida, on the 11th day of January, 2022,

/s/ William M. Windsor_____________

William M. Windsor, Proudly Pro Se
100 East Oak Terrace Drive, Unit B3
Leesburg, Florida 34748
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CERTIFICATE OF SERVICE

I hereby certify that I have served the foregoing as follows:

The Delaney at Lake Waco, LCS Waco Operations LLC, Life Care Companies LLC, Joel Nelson, Scott Bushong, Paula Smith, Alyssa Claridy, Marlene Morrison, Alma Morrow, Connie Moore, Sandra Robinson, M. Margaret:

LEWIS, BRISBOIS, BISGAARD & SMITH, LLP
2100 Ross Avenue, Suite 2000, Dallas, Texas 75201
214-722-7100 – Fax: 214-722-7111
Susan E. Briones State Bar No. 24040523 This email address is being protected from spambots. You need JavaScript enabled to view it.
Nichol L. Bunn State Bar No. 00790394 This email address is being protected from spambots. You need JavaScript enabled to view it.

Dr. David Fedro:

Fee, Smith, Sharp & Vitullo, LLP
Three Galleria Tower
13155 Noel Road, Suite 1000, Dallas, Texas 75240
972-980-3262 – Fax: 972-934-9200

Craig H. Myers This email address is being protected from spambots. You need JavaScript enabled to view it.

Barbara D. Weir:

SPROTT NEWSOM QUATTLEBAUM & MESSENGER, PC
MICHELE QUATTLEBAUM
State Bar No. 16423400
2211 Norfolk St., Suite 1150, Houston, Texas 77098
713-523-8338 – 713-523-9422
This email address is being protected from spambots. You need JavaScript enabled to view it.


Doug Dutschmann, Michael Dutschmann, Krissy Matthews:

DUNNAM & DUNNAM LLP
4125 West Waco Drive, Waco, Texas 76714-8418
254-753-6437 Fax: 254-753-7434
JIM DUNNAM State Bar No. 06258010
MASON VANCE DUNNAM State Bar No. 24108079
This email address is being protected from spambots. You need JavaScript enabled to view it., This email address is being protected from spambots. You need JavaScript enabled to view it., This email address is being protected from spambots. You need JavaScript enabled to view it.


Kerri Jill Perryman:

c/o Doug Dutschmann, Hatada Ranch, 150 FM-854, Valley Mills, TX 76689, 254-644-3283
This email address is being protected from spambots. You need JavaScript enabled to view it.


City of Waco, Waco Police Department, Detective John Clark, Officer Tyler Green, Officer Paul Law:

HALEY & OLSON, P.C.
100 N. Ritchie Road, Suite 200
Waco, Texas 76712
(254) 776-3336 -- Telecopier: (254) 776-6823
BRANDON R. OATES, State Bar No. 24032921, This email address is being protected from spambots. You need JavaScript enabled to view it.
DAVID SHAW, State Bar No. 24084641, This email address is being protected from spambots. You need JavaScript enabled to view it.


American Medical Response

6800 Woodway Drive, Woodway, Texas 76712, 833-267-9226, Fax: 833-922-3292
This email address is being protected from spambots. You need JavaScript enabled to view it.

 
William Michael Windsor:

100 East Oak Terrace Drive, Unit B3
Leesburg, Florida 34748
This email address is being protected from spambots. You need JavaScript enabled to view it.


Marcie Schreck

6302 Oakcrest Lane
Amarillo, Texas 79109
254-651-7078
This email address is being protected from spambots. You need JavaScript enabled to view it.


This 10th day of January, 2022,                                                        

/s/ William M. Windsor_____________

William M. Windsor, Proudly Pro Se
100 East Oak Terrace Drive, Unit B3
Leesburg, Florida 34748
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Copyright LawlessAmerica.com




Bill Windsor graduated from Monterey High School and Texas Tech University in Lubbock, Texas -- not too far from Waco, Texas.  This gives him a special interest in exposing the scum in the area of the country he has loved so much. 



windsor bill 1979 closeup of bill tan 1979 200w

Bill Windsor


I, William M. Windsor, am not an attorney.  This website expresses my OPINIONS.   The comments of visitors or guest authors to the website are their opinions and do not, therefore, reflect my opinions.  Anyone mentioned by name in any article is welcome to file a response.   This website does not provide legal advice.  I do not give legal advice.  I do not practice law.   This website is to expose government corruption, law enforcement corruption, political corruption, and judicial corruption.   Whatever this website says about the law is presented in the context of how I or others perceive the applicability of the law to a set of circumstances if I (or some other author) was in the circumstances under the conditions discussed.  Despite my concerns about lawyers in general, I suggest that anyone with legal questions consult an attorney for an answer, particularly after reading anything on this website.  The law is a gray area at best.  Please read our Legal Notice and Terms

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