Thursday, June 22, 2017

California lawyer Ashley Conlogue dumped her as a client? Conlogue appears to have been fired.

It appears that * no longer has legal representation in Los Angeles, California. Did her attorney dump her because she lied to her attorney and the court? Did the law firm fire Ashley Conlogue after she was severely reprimanded and sanctioned by Judge Robert Hess? Who knows. Still the attorney or firm had to notify the court the moment they no longer represented her. They did not because I bet * instructed them not to do so. That means they legally were representing her for the last few months. The law firm is still liable for removing my confidential data from online.

There was an automatic court update to my California case. The clerk stated that email to Ashley Conlogue was not being answered. The Court stated they received this reply,

"I am away from the office beginning Friday, May 19, 2017.  This email address is not being forwarded to another attorney at the firm.  Thus, if you have received this message, please re-send your correspondence to Christian S. Molnar, at, and Neelam Molnar, at

Court then stated this,

"Arendsen Cane Molnar Law:
          Ms. Conlogue automatic email notification has advised that she is out of the office and to forward her emails to Christian S. Molnar, at, and Neelam Molnar, at
          If Ms. Conlogue is no longer the handling attorney in this matter please serve and file a change of handling attorney with this Court within 5 days of the date of this email.
          Please do not email it directly to me; consider E-filing at:
          Thank you,

Becky L. Fisher, Supervising Deputy Clerk"

The court contacted Christian Molnar today 062217 and received this reply,

"Subject: Re: B278893 - Bat World Sanctuary et al v. Cummins [ Trial Court Case No: BS140207 ]

We haven't been the attorneys of record for several months.


Christian S. Molnar
Litigation Attorney
Arendsen Cane Molnar LLP
Beverly Hills—San Diego
315 S. Beverly Dr.,Suite 320
Beverly Hills, California 90210

Then the court sent this email. Clerk doesn't realize Christian is a male,

"Ms. Molnar:
          Please file a substitution of attorney. Our records reflect that Conlogue of Arendsen Cane Molnar, LLP remain as counsel for respondent.  Until receive notice otherwise, Arendsen remains as counsel of record.
Thank you,

Becky L. Fisher, Supervising Deputy Clerk "

Mary Cummins vs Randy Turner, Randall Turner, Randall E Turner, Randall Eugene Turner, attorney, lawyer, fort worth, texas, tarrant county, second court of appeals, 352-248169-10, 352nd District Court, Judge Bonnie Sudderth, Justice Bonnie Sudderth, Judge William Brigham, Justice William Brigham, 2015-002259-2, 2015-002259-3, 02-12-00285-CV, 02-16-00165-CV, county court 3, Judge Mike Hrabal, Mike Hrabal, Judge Jennifer Rymell, Jennifer Rymell, defamation, libel, slander, breach of contract, forgery, fraud, perjury, disbar, unethical, unprofessional, inappropriate

Friday, June 9, 2017

Amicus letter filed on my behalf. Case submitted to Appeals Court. Mary Cummins, freedom of speech.

An amicus brief was filed on my behalf. They're not arguments I didn't raise but I'm still thankful. Time will tell if there will be justice in Texas. In the meantime Randy Turner and his client Amanda Lollar keep posting crazy, libelous material about me. I'm not even going to mention the crazy things. Turner is an attorney. He knows full well what he is doing is wrong and libelous.


June 6, 2017

Fax 806 342 2650
Clerk, Court of Appeals
Seventh District of Texas
Potter County Courts Building
501 S. Fillmore, Suite 2-A
Amarillo, Texas 79101-2449

RE: Case Number: 07-16-00337-CV, Trial Court Case Number: 2015-002259-3, Cummins v. Lollar

To the Court of Appeals for the Seventh District of Texas:

     I write as a proponent of free speech an amicus curiae to express the following concerns about the motion to dismiss a cause for defamation that is under appeal. I have an interest in libel law and the application of fair procedures for resolving such libel suits.

     I file this amicus curiae using only initials. The last two lawyers who filed amicus curiae in the previous identical case, David Cassellman and Paul Alan Levy of Public Citizen, were harassed and defamed by Plaintiff Ms. Lollar and her lawyer. A woman claiming to be a lawyer from Mr. Turner's office contacted the lawyers to defame Defendant Cummins and demand that their amicus be retracted. The lawyers refused. Thereafter Plaintiff Ms. Lollar and her lawyer harassed these lawyers on the internet on multiple blogs and websites.

     The Supreme Court has ruled repeatedly that the right to anonymous free speech is protected by the First Amendment. A frequently cited 1995 Supreme Court ruling in McIntyre v. Ohio Elections Commission reads, “Anonymity is a shield from the tyranny of the majority. . . It thus exemplifies the purpose behind the Bill of Rights and of the First Amendment in particular: to protect unpopular individuals from retaliation . . . at the hand of an intolerant society.”

Facts and Statements of the Case

     A previous similar case was filed by Plaintiff Ms. Lollar and Bat World Sanctuary against Defendant Cummins in 2010, 352-248169-10. In that case Plaintiff never stated what items they believed were defamatory. Plaintiff never stated that Plaintiff Ms. Lollar suffered any damages or showed proof of any damages or causation. Plaintiff has not had a paying job in over 25 years. Plaintiff did not show the elements of defamation or breach of contract. Plaintiff waited until the last minute of their closing argument to ask the Judge for the first time for an award in the range of four to eight million dollars for Plaintiff Ms. Lollar. Judge Brigham awarded $6,000,000 in defamation damages to Plaintiff Ms. Lollar, $176,000 in legal fees and $10,000 in liquidated damages.

     Defendant Cummins appealed. Two amicus briefs were written on behalf of Defendant by the previously mentioned lawyers. The Appeals court reversed the breach of contract claims, lawyer’s fees and liquidated damages. Through an 18 months long act of legal gymnastics, misquoting the record, making false assumptions, misinterpreting common law that undermined the rule of law the defamation judgment of $6,000,000 remained.

     It should be noticed here that lawyer Mr. Turner has a special relationship with the Justices in the Second Court of Appeals. Mr. Turner has stated many times to the media that he wanted to be the first attorney to find for sentimental value of a dog. Mr. Turner stated it was his main goal for his legal career. In Medlens v Carla Strickland, 02-11-00105-CV, the three Justice panel voted unanimously for the Medlens. They ruled that dogs can have great sentimental and monetary value even though all case law states dogs are considered personal property.
     Strickland, an Animal Control Officer at a public animal shelter, appealed to the Supreme Court of Texas. Many amicus briefs were submitted on behalf of Strickland. Justice Willett who wrote the opinion upheld the 126-year-old precedent maintaining pets as personal property. The Supreme Court was unanimous in its decision overturning the lower Court’s unanimous decision. Justice Willett even stated on the record to lawyer John Cayce who represented Strickland that the case should have been dismissed in the trial court. Cayce who was previously the Chief Justice of the Second Court of Appeals of Texas agreed and stated “my old court got it wrong.” So too did the panel on the previous case here quite possibly because of the same close relationship between Mr. Turner, his wife, also a lawyer, and the Justices of the Second Court of Appeals. For these reasons the Supreme Court of Texas transferred the case from the Second Court of Appeals to the Seventh Court of Appeals of T

     In this current case Plaintiff Ms. Lollar filed another complaint for defamation against Defendant Cummins mere days after the Appeals Court released its opinion. It’s just about an exact duplicate of the initial 2010 complaint. The complaint again had no exhibits and did not state what Plaintiff believed was defamatory. It also referenced an alleged contract which the Appeals Court had reversed to try to claim jurisdiction in Tarrant County, Texas.

     Since the previous case was filed Texas has worked to reduce the massive amount of frivolous defamation lawsuits meant to stifle freedom of speech such as this case. The Texas Citizens Participation Act was signed into law on June 17, 2011 to help protect Freedom of Speech. June 14, 2013 Governor Perry also signed into law HB 1759 adopting the Defamation Mitigation Act demonstrating continued support of free speech for all. The bill was passed by more than a two-thirds majority of each chamber and, as a result, it became law on June 14, 2013.

     July 2015 Defendant filed a Motion to Dismiss per the Citizen Participation Act, Defamation Mitigation Act, Statute of Limitations and Lack of Jurisdiction. September 2015 Plaintiff filed a reply to the Motion to Dismiss. Defendant then filed an amended Motion to Dismiss also adding the causes of forgery and perjury as Plaintiff forged their exhibits. Because Defendant has never defamed Plaintiff, Plaintiff had to forge exhibits all conveniently just barely within the statute of limitations. Almost every blog and Twitter account they include as evidence do not exist on the Internet. Plaintiff signed a sworn declaration stating the exhibits were exact copies of the originals which are still located online in their original form. Plaintiff even included three different copies of a forged email from the head of the Federal USDA which amounts to impersonating a Government Official. That emails cleared Plaintiff Ms. Lollar of all violations of the Animal Welfare Act even thou
 gh Ms. L
 ollar lost her USDA permit years earlier because she caused bats “pain, suffering,” “death,” and “violated the Animal Welfare Act.” That forged email and a 2011 real email from the main veterinarian of the USDA are the basis of Ms. Lollar’s current defamation case. Defendant didn’t write either of the years old emails. Ms. Lollar is merely embarrassed by her cruel actions and wants the items removed from the Internet. Plaintiff’s exhibits are not exact copies of the original documents or even any document. This is perjury.

     Plaintiff’s lawyer Mr. Turner knows his client committed forgery and perjury yet Mr. Turner did not notify the Court as he must per Tex. Disciplinary R. Prof. Conduct, 2011 Rule 1.05(g)(h), Rule 1.02(c), “A lawyer shall not assist or counsel a client to engage in conduct that the lawyer knows is criminal or fraudulent.”

     This behavior is also a violation of Rule 3.03(a)(1)(2)(5), “Candor Toward the Tribunal; (a) A lawyer shall not knowingly: (1) make a false statement of material fact or law to a tribunal; (2) fail to disclose a fact to a tribunal when disclosure is necessary to avoid assisting a criminal or fraudulent act; (5) offer or use evidence that the lawyer knows to be false;(b) If a lawyer has offered material evidence and comes to know of its falsity, the lawyer shall make a good faith effort to persuade the client to authorize the lawyer to correct or withdraw the false evidence. If such efforts are unsuccessful, the lawyer shall take reasonable remedial measures, including disclosure of the true facts.”

     For these reasons Plaintiff Ms. Lollar should be prosecuted. Plaintiff’s lawyer Mr. Turner should be prosecuted and disciplined by the State Bar of Texas.

The Court Order Should Be Reversed Under the Doctrine of Unclean Hands.

     Because Plaintiff forged the exhibits and committed perjury in a sworn statement, Plaintiff has unclean hands. The defense of “unclean hands,” which bars equitable relief when the Plaintiff “has engaged in unlawful or inequitable conduct with regard to the issue in dispute” and such conduct has injured the Defendant, See In re Francis, 186 S.W.3d 534, 551 (Tex 2006) (Wainwright, dissenting) (citing Right to Life Advocates, Inc. v. Aaron Women's Clinic, 737 S.W.2d 564, 571–72 (Tex. App.-Houston [14th Dist.] 1987, writ denied) and Grohn v. Marquardt, 657 S.W.2d 851, 855 (Tex. App. San Antonio 1983, writ ref'd)); see also Truly v. Austin, 744 S.W.2d 934, 938 (Tex. 1988) (“It is well-settled that a party seeking an equitable remedy must do equity and come to court with clean hands.”).

     Plaintiff Ms. Lollar does not come with clean hands. The fact that Ms. Lollar had to forge defamatory exhibits against herself shows that there is no real evidence of defamation to be found. There is no need to even argue defamation at this point even though Defendant Ms. Cummins does argue defamation in appeal.


     For these reasons, the Court should reverse the court order and dismiss the underlying trial case. Furthermore the Court should refer Plaintiff Ms. Lollar for prosecution and Plaintiff’s lawyer Mr. Turner for prosecution and discipline by the State Bar of Texas.

Respectfully yours,


cc: Randall Turner, Esquire, Fax 817 887 5717
    Mary Cummins, Pro Se, Fax 310 494 9395

Mary Cummins vs Amanda Lollar, Mary Cummins, Amanda Lollar, Bat World, Bat World Sanctuary, Randy Turner, Randall Turner, Randall E Turner, Randall Eugene Turner, attorney, lawyer, fort worth, texas, tarrant county, second court of appeals, 352-248169-10, 352nd District Court, Judge Bonnie Sudderth, Justice Bonnie Sudderth, Judge William Brigham, Justice William Brigham, 2015-002259-2, 2015-002259-3, 02-12-00285-CV, 02-16-00165-CV, county court 3, Judge Mike Hrabal, Mike Hrabal, Judge Jennifer Rymell, Jennifer Rymell, defamation, libel, slander, breach of contract, forgery, fraud, perjury, disbar, unethical, unprofessional, inappropriate