No. 00-00619
THE LAW OFFICES OF )( IN THE DISTRICT COURT
G. DAVID WESTFALL, P.C. )(
)( 294TH JUDICIAL DISTRICT
Vs. )(
)( VAN ZANDT COUNTY, TEXAS
UDO BIRNBAUM )(
)(
Vs. )(
)(
G. DAVID WESTFALL )(
)(
CHRISTINA WESTFALL )(
)(
STEFANI PODVIN )(
)(
John Doe )(
Mary Doe )(
APPENDIX
TO UDO BIRNBAUM'S RESPONSE
TO MOTIONS FOR SUMMARY JUDGMENT
EXHIBITS 1-7: On file with Pleadings.
EXHIBIT 8: Transcript of 9/20/2000 G. David Westfall Bankruptcy trial. On file.
EXHIBIT 9: Regarding G. David Westfall Conduct. See Exhibit 9 Index.
EXHIBIT 10: Videotaped Deposition of Udo Birnbaum -TRANSCRIPT
EXHIBIT 11: Vide otaped Deposition of Udo Birnbaum - EXHIBITS
EXHIBIT 12: Videotaped Deposition of David Westfall - TRANSCRIPT
EXHIBIT 13: Videotaped Deposition of David Westfall - EXHIBITS
EXHIBIT 14: Videotaped Deposition of Christina Westfall - ALL
EXHIBIT 15: Videotaped Deposition of Stefani Podvin - ALL
EXHIBIT 16: Re: Westfall role: Fifth Circuit Sanctions Appeal - BRIEF
EXHIBIT 17: Re: Westfall role: Fifth Circuit Sanctions Appeal - RECORDS
NOTICE OF INTENT PURSUANT TO RULE 166a(d)
to use discovery products to oppose the summary judgment
NOTICE is hereby given of Udo Birnbaum's intent to use the volumes and exhibits named above to oppose summary judgment. Notice is also given of intent to oppose summary judgment by reference to all other discovery documents, whether requests, answers or failure to provide such, or pending motions relating thereto.
___________________
UDO BIRNBAUM, Pro Se
540 VZ 2916
Eustace, Texas 75124
(903) 479-3929
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of this document has been served via Regular Mail and Fax on this the _____ day of August, 2001 upon G. David Westfall, 5646 Milton, Suite 520, Dallas, Texas 75206 and Frank C. Fleming, Law Office of Frank C. Fleming, 6611 Hillcrest, Suite 305, Dallas, Texas 75205-1301. Only Volumes 1, 8, and 9 is provided with this mailing. The other material has either been previously provided to the above, or was provided by the court reporter at the same time the copy was provided to Birnbaum.
___________________
UDO BIRNBAUM
EXHIBIT 9
REGARDING G. DAVID WESTFALL CONDUCT
Exh.
9-A Account Work Sheet. Analysis of Westfall "bill" shows it to be a fraud
9-B Affidavit of Michael Collins (8/29/2001) regarding Westfall soliciting suits against public officials and regarding fraudulent Westfall "bill"
9-C Affidavit of Kathy Young (8/30/00) regarding Westfall soliciting suits against public officials and regarding Westfall backdating the "bill"
9-D Affidavit of Marjorie Phelps (8/30/00) of Westfall soliciting suits against public officials
9-E Affidavit of Kathy Young (8/23/2000) of Westfall soliciting Birnbaum
9-F Finding of Westfall abusing the legal process
9-G Finding of Westfall violating Bar rules by soliciting clients
9-H Order re: Westfall community supervision for cruelty to animals
9-J Investigator's report re: Westfall cruelty to animals
9-K Affidavit of Westfall's ranch manager re: Westfall instruction to hide evidence
9-L Affidavit of Christina Westfall (3/20/1998) showing she is intimately involved
9-M Deposition of Berverly Hearn showing Christina Westfall is intimately involved
9-N Westfall fraud in Bankruptcy Court claiming he had more than 12 valid creditors
9-O Fifth Circuit Pattern Civil RICO jury instructions