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Subject: Fw: Patriot theories crash and burn
in one fell swoop in credit card case against bank
Date: Fri, 7 Aug 2009 18:19:12 -0500
From: GTO <[email protected]>
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Sent: Friday, August 07, 2009 3:10 PM
Subject: Patriot theories crash and burn
in one fell swoop in credit card case against bank
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----- Original Message -----
From: chancellor
Sent: Thursday, August 06, 2009 10:49 AM
Subject: Patriot theories crash and burn
all of them in one fell swoop credit card case against bank


Opinion issued June 9, 2005
In The Court of Appeals For The First District of Texas
NO. 01-04-00422-CV

JAMES CAVAZOS, Appellant
V.
CITIBANK (SOUTH DAKOTA), N.A., Appellee

On Appeal from County Civil Court at Law No. 3
Harris County, Texas
Trial Court Cause No. 794,090

MEMORANDUM OPINION
            James Cavazos, appellant and defendant below, appeals
            a summary judgment awarding money damages to appellee,
            Citibank (South Dakota), N.A. ("Citibank"). Appellant
            presents the following seven issues on appeal: (1) summary
            judgment pursuant to rule 185 of the Texas Rules of Civil
            Procedure was improper because the account in question
            was not a sworn account; (2) Citibank is a national bank
            and cannot legally "loan credit"; (3) the original note,
            bookkeeping entries, accounting ledgers, and allonge,
            were not produced by Citibank; (4) appellant discharged
            his debt to Citibank "via bond and public policy does not
            require the payment of a debt to be in any particular
            type of currency of the United States"; (5) appellant
            "offered to discharge said debt per Texas Business
            and Commercial Code article 2 section 603," even if
            Citibank "refused to accept the form of payment offered";
            (6) appellant was "denied equal protection under the
            law per the XIV amendment of the U.S. Constitution";
            and (7) appellant is a sovereign, exempt from levy,
            or is a secured creditor, with a prior UCC lien that is
            superior in priority to Citibank's judgment against the
            fictitious entity named "JAMES CAVAZOS" and not against
            him as a human being. We affirm.

BACKGROUND
            Appellant obtained a credit card from Citibank and
            used the card to make purchases and receive cash
            advances. Appellant used the credit card for four
            years. He did not make payments as required by the
            terms of his agreement with Citibank. The total balance
            due on appellant's credit card account was $11,649.85,
            according to the verified statement of account filed
            with Citibank's original petition and motion for summary
            judgment. Requests for admission were also attached to the
            petition. In response to the lawsuit, appellant filed a
            document entitled "Verified Declaration in the Nature of
            an Affidavit for Truth in Commerce and Contract for Waiver
            Of Tort Presented by me, addressee, James G. Cavazos,
            living sole [sic], one of We the People under Original
            Common Law jurisdiction of Texas and united [sic] States
            Contracts, the Constitution." Appellant did not respond to
            the requests for admission. Citibank filed a rule 166a(c)
            motion for summary judgment.  Appellant did not file a
            response to Citibank's motion but appeared pro se at the
            hearing on the motion. The trial court entered summary
            judgment in favor of Citibank on March 15, 2004.


DISCUSSION
            A party moving for a summary judgment has the burden
            of proving that there is no genuine issue of material
            fact and that the movant is entitled to judgment
            as a matter of law. Tex. R. Civ. P. 166a(c); Nixon
            v. Mr. Prop. Mgmt. Co.,690 S.W.2d 546, 548 (Tex. 1985);
            Tesoro Petroleum Corp. v. Nabors Drilling USA, Inc.,
            106 S.W.3d 118, 124 (Tex. App. Houston [1st Dist.] 2002,
            pet. denied.). When deciding whether there is a disputed
            material fact issue precluding summary judgment, evidence
            favorable to the nonmovant will be taken as true. Nixon,
            690 S.W.2d at 548 49. Every reasonable inference must
            be indulged in favor of the nonmovant and any doubts
            resolved in its favor. Id.

            In his first issue, appellant argues that summary judgment
            under rule 185 was improper because his account with
            Citibank was not a sworn account.  Appellant cites a case
            in which the El Paso court of appeals held that a credit
            card that was issued for the purpose of lending money
            through cash advances and buying goods and services from
            third parties was not a sworn account as contemplated by
            rule 185. See Bird v. First Deposit Nat'l Bank, 994 S.W.2d
            280, 282 (Tex. App. El Paso 1999, pet. denied). While it
            is true that Citibank's motion cannot prevail under rule
            185, appellant's argument assumes that Citibank's motion
            for summary judgment relied exclusively on the assertion
            that the credit card account was a properly pleaded
            "sworn account." Appellant's assumption is incorrect and,
            therefore, his reliance on Bird is misplaced.

Citibank's pleadings presented a claim for breach of contract
            and its motion for summary judgment provided competent
            summary judgment evidence on that claim. In particular,
            the deemed admissions included an admission by appellant
            that he had breached his contract and owed Citibank
            $11,649.85. We overrule appellant's first issue.

            In his second issue, appellant claims that Citibank
            is a national bank and is barred from "loaning
            credit." Appellant's argument is without merit; Citibank
            may issue credit cards and charge interest on the cash
            advances and purchases its cardholders make using those
            cards. See, e.g., National Bank Act, 12 U.S.C.S.   85
            (Law. Co-op. 1994);Patten v. Maryland Bank, N.A., 126
            S.W.3d 532, 533 34 (Tex. App. Houston [1st Dist.] 2003,
            pet. denied) (noting that Delaware national bank could
            charge interest in excess of amount allowed by Texas law
            on credit card issued to Texas resident). We overrule
            appellant's second issue.

            In his third issue, appellant contends that Citibank
            should have been required, under rule 1002 of the
            Texas Rules of Evidence, to produce original copies of
            certain loan documents. Even if appellant had objected
            to Citibank's proffer of copies of these documents, and
            the record before us does not show that he made such an
            objection, the trial court could have properly admitted
            the copies under rule 902(10), as the record shows that
            Citibank attached a business records affidavit in the
            proper form. See Tex. R. Evid. 902(10). We overrule
            appellant's third issue.

            In his fourth issue, appellant argues that he tendered
            a "bond" to Citibank and thereby discharged his debt
            because, under Guaranty Trust Co. v. Henwood, the Supreme
            Court recognized that Congress had proscribed a creditor
            from requiring a debtor to pay in "a particular kind of
            coin or currency of the United States." 307 U.S. 247,
            252-53, 59 S. Ct. 847, 850 51 (1939). Appellant not
            only misreads Guaranty Trust but he fails to cite any
            evidence in the record to support his contention that
            he presented Citibank with his "bond.". We overrule
            appellant's fourth issue.

            In his fifth issue, appellant reprises his argument that
            his "bond" discharged his debt to Citibank as provided
            by the Texas Business and Commerce Code, article 3,
            section 603. See Tex. Bus. & Com. Code Ann.   3.603
            (Vernon 2002). The authorities appellant cites in
            support of this assertion are misrepresented, miscited,
            mischaracterized, or are complete non sequiturs. Appellant
            has presented no authority or evidence that Citibank
            was under any obligation to accept payment via the
            allegedly tendered "bond" or promissory note. See
            Re/Max of Texas, Inc. v. Katar Corp., 961 S.W.2d 324,
            328 (Tex. App. Houston [1st Dist.] 1997, pet. denied)
            (concluding that appellant's failure to make argument,
            cite authority, or refer to record in support of
            contention resulted in nothing for court to review). We
            overrule appellant's fifth issue.

            In his sixth issue, appellant argues that the trial court
            violated his right to equal protection by rendering
            summary judgment because Citibank did not make full
            disclosure of all material facts so that appellant "could
            fully understand that agreement, specifically that the
            bank 'created' money by depositing his signed promissory
            note, thus funding the 'loan,' [and] then [his] loan
            would be canceled." We understand appellant's argument
            to be that Citibank must accept a promissory note from
            him as payment to discharge his debt. Appellant cites no
            authority for this argument. For the same reasons given
            for overruling his fifth issue, we overrule appellant's
            sixth issue.

            In his seventh issue, appellant argues that he is his
            own secured creditor, with superior priority over any
            claim Citibank may have over his assets and that he is a
            sovereign exempt from levy under the "Foreign Sovereign
            Immunities Act."

            Appellant's secured creditor claim apparently stems
            from the fact that his name is spelled in all capital
            letters on Citibank's pleadings and on the judgment
            rendered against him. Appellant contends that his name
            must be spelled in capital and lower case letters
            and that only the names of corporations are spelled
            with all capital letters. Appellant asserts that,
            subsequent to the rendering of judgment, he filed a
            financing statement, a UCC-1 form, against the fiction
            "JAMES CAVAZOS" giving him superior lien priority
            on that fictitious entity's assets. Appellant also
            asserts that Citibank has no valid judgment against him
            "as a human being." Citibank contends that appellant's
            theories fall under the legal category of "gobbledygook."
            In his seventh issue, appellant does not cite to any
            relevant portion of the record, or to any relevant
            authority, and does not present any comprehensible
            issue for our review. See Tex. R. App. P.38.1(h);
            Massey v. Royall, No. 14-02-01260-CV, 2004 WL 114989,
            at *1 (Tex. App. Houston [14th Dist.] Jan. 27, 2004,
            no pet.) (not designated for publication) (holding that
            pro se appellant's incomprehensible issue could not
            be addressed); Serrano v. Union Planters Bank, N.A.,
            No. 08-03-00101-CV, 2004 WL 2849484, at *1 (Tex. App. El
            Paso, Dec. 2, 2004, no pet. h.) (refusing to address
            seventeen of pro se appellant's eighteen issues because
            they were "virtually incomprehensible and nonsensical and
            do not frame any issues for review by this court"). We
            overrule appellant's seventh issue.

                                                       CONCLUSION
            We affirm the judgment of the trial court.

                                                      Sam Nuchia

Justice Panel consists of Justices Nuchia, Jennings, and Alcala.



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