Amanda Lollar, Bat World Sanctuary in contempt of court. They did not follow the Judge's orders. They were supposed to give me all of their financial documents but they did not. I filed a motion for contempt. It is linked below. Directly below is the text from the pdf file. I am not posting any of their financial documents. This is a public legal document I filed. Amanda Lollar, Bat World Sanctuary are in contempt of court.
TO THE HONORABLE JUDGE OF SAID COURT:
Now comes the Defendant Mary Cummins, Defendant Pro se, movant herein and requests that Plaintiffs be found and held in contempt of court. In support of this motion, Movant will show the Court the following:
I.
On March 15, 2012 this court signed an order (Exhibit 1) ordering Plaintiffs, Amanda Lollar, Bat World Sanctuary to “produce monthly bank statements, PayPal records, and credit card records for the preceding two years but that all names, addresses, and account numbers may be redacted. It is further ordered that Bat World Sanctuary shall produce mortgage statements pertaining to the real property at 217 N. Oak Street, Mineral Wells, Texas and 115 N.E. 1st Street, Mineral Wells, Texas for the preceding year but that all account numbers may be redacted.” Plaintiffs have failed to provide these documents to Defendant as ordered. Their response is not attached to this file as Defendant is not allowed to share the documents. The documents will be produced at the hearing under seal to the Judge.
Plaintiffs redacted EVERYTHING in the bank statements, PayPal records and credit card reports. Deposits and withdrawals were deleted. Only a monthly balance is shown. Defendant needs to know how much money came in and how much money went out. The balance could be for example $5,000 even if $100,000 were deposited and withdrawn every month or if $0 were deposited and withdrawn. Defendant must see if there are financial damages. Defendant has knowledge that Plaintiffs are making more money than ever before. Plaintiffs have no financial damages. Plaintiffs also did not provide all documents in original form. Some were copy/pasted into what appears to be a spread sheet. These items could have been altered. Defendant must have these documents in their original form. Defendant requested these items from Plaintiffs’ attorney Randy Turner. Turner did not reply.
Plaintiffs provided records for 2010 and 2011. Defendant requested preceding two years, i.e. previous 24 months. Defendant has knowledge that Plaintiffs have received considerably more donations and income than ever before. In Plaintiffs’ April 6, 2012 deposition in the Federal libel and defamation lawsuit against Plaintiffs, Plaintiff Amanda Lollar admitted to receiving a $25,000 grant. Plaintiff also admitted receiving $14,000 from another group in 2011. Plaintiff has knowledge or other considerable financial transactions which do not appear in any of the financial documents given to Defendant.
Defendant asked for mortgage statements pertaining to both properties at 217 N. Oak Street, and 115 N. E. 1st Street, Mineral Wells, Texas. Plaintiff admitted in her November 8, 2011 deposition in Texas to having a mortgage on the property at 217 N. Oak. This mortgage information was not provided to Defendant, only the mortgage information for the building located at 115 N. E. 1st Street. Plaintiffs should be held in contempt of court for her refusal to comply with the Court’s order.
WHEREFORE, PREMISES CONSIDERED, Defendant requests that the court hold Amanda Lollar, Bat World Sanctuary in contempt of Court and order her to pay all travel expenses and associated costs and for such other and further relief as may be equitable in law or in equity.
Respectfully submitted,
Mary Cummins, Defendant Pro se
645 W 9th St, #110-140
Los Angeles, CA 90015-1640
Phone 310-877-4770
Email: mmmaryinla@aol.com
By: ________________________________
Mary Cummins, Defendant Pro Se
http://www.animaladvocates.us/batWorldLawsuit/motion_contempt_amanda_lollar.pdf
Mary Cummins of Animal Advocates is a wildlife rehabilitator licensed by the California Department of Fish and Game and the USDA. Mary Cummins is also a licensed real estate appraiser in Los Angeles, California.
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| Amanda Lollar, Bat World Sanctuary, in contempt of court |
MOTION FOR CONTEMPT
TO THE HONORABLE JUDGE OF SAID COURT:
Now comes the Defendant Mary Cummins, Defendant Pro se, movant herein and requests that Plaintiffs be found and held in contempt of court. In support of this motion, Movant will show the Court the following:
I.
On March 15, 2012 this court signed an order (Exhibit 1) ordering Plaintiffs, Amanda Lollar, Bat World Sanctuary to “produce monthly bank statements, PayPal records, and credit card records for the preceding two years but that all names, addresses, and account numbers may be redacted. It is further ordered that Bat World Sanctuary shall produce mortgage statements pertaining to the real property at 217 N. Oak Street, Mineral Wells, Texas and 115 N.E. 1st Street, Mineral Wells, Texas for the preceding year but that all account numbers may be redacted.” Plaintiffs have failed to provide these documents to Defendant as ordered. Their response is not attached to this file as Defendant is not allowed to share the documents. The documents will be produced at the hearing under seal to the Judge.
Plaintiffs redacted EVERYTHING in the bank statements, PayPal records and credit card reports. Deposits and withdrawals were deleted. Only a monthly balance is shown. Defendant needs to know how much money came in and how much money went out. The balance could be for example $5,000 even if $100,000 were deposited and withdrawn every month or if $0 were deposited and withdrawn. Defendant must see if there are financial damages. Defendant has knowledge that Plaintiffs are making more money than ever before. Plaintiffs have no financial damages. Plaintiffs also did not provide all documents in original form. Some were copy/pasted into what appears to be a spread sheet. These items could have been altered. Defendant must have these documents in their original form. Defendant requested these items from Plaintiffs’ attorney Randy Turner. Turner did not reply.
Plaintiffs provided records for 2010 and 2011. Defendant requested preceding two years, i.e. previous 24 months. Defendant has knowledge that Plaintiffs have received considerably more donations and income than ever before. In Plaintiffs’ April 6, 2012 deposition in the Federal libel and defamation lawsuit against Plaintiffs, Plaintiff Amanda Lollar admitted to receiving a $25,000 grant. Plaintiff also admitted receiving $14,000 from another group in 2011. Plaintiff has knowledge or other considerable financial transactions which do not appear in any of the financial documents given to Defendant.
Defendant asked for mortgage statements pertaining to both properties at 217 N. Oak Street, and 115 N. E. 1st Street, Mineral Wells, Texas. Plaintiff admitted in her November 8, 2011 deposition in Texas to having a mortgage on the property at 217 N. Oak. This mortgage information was not provided to Defendant, only the mortgage information for the building located at 115 N. E. 1st Street. Plaintiffs should be held in contempt of court for her refusal to comply with the Court’s order.
WHEREFORE, PREMISES CONSIDERED, Defendant requests that the court hold Amanda Lollar, Bat World Sanctuary in contempt of Court and order her to pay all travel expenses and associated costs and for such other and further relief as may be equitable in law or in equity.
Respectfully submitted,
Mary Cummins, Defendant Pro se
645 W 9th St, #110-140
Los Angeles, CA 90015-1640
Phone 310-877-4770
Email: mmmaryinla@aol.com
By: ________________________________
Mary Cummins, Defendant Pro Se
http://www.animaladvocates.us/batWorldLawsuit/motion_contempt_amanda_lollar.pdf
Mary Cummins of Animal Advocates is a wildlife rehabilitator licensed by the California Department of Fish and Game and the USDA. Mary Cummins is also a licensed real estate appraiser in Los Angeles, California.
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