Two hearing are set for January 22, 2002 in the Nueces County Courthouse
in Corpus Christi. The address is 901 Leopard and the hearings will
take place in the first floor courtroom.
The first hearing starts at 10:00 a.m. and involves the following:
- Our Motion to Compel the Kenedy Foundation to answer the interrogatories
and requests for production needed to prove that in addition to Kenedy
County, we cannot get a fair trial in either Kleberg or Nueces County;
- Our Motion for a Protective Order to prevent the Kenedy Foundation
from taking depositions of certain family members including myself,
until after the Motion to Change Venue has been decided. We are keeping
the focus on getting the case moved from Kenedy County to a county
where we can get a fair trial;
- Our Motion for New Scheduling Order to get back the time we lost
caused by the Kenedy Foundation's delay in responding to our discovery
requests as well as other things done to delay the case;
- The Kenedy Foundation's motion to add all "unknown and unborn"
heirs of Jose Manuel Balli Villarreal to this lawsuit. If granted,
any heirs who have not already gotten involved will be sued in the
newspaper in Kingsville, Texas! Any primary heirs who have not already
done so should immediately hire an attorney;
- The Kenedy Foundation's motions to compel the depositions of Gloria
Munoz Gibney, Joe Balli and myself; and
- The Kenedy Foundation's motion to compel the Delia Pina Flores
group to respond to discovery. This group recently hired our primo,
Ballí-Patton to fight for them, which makes the fourth lawyer
in the case to refer his clients to Hector Cárdenas and more
are in the process of hiring him.
The second hearing starts at 1:00 p.m. and involves:
- Our Motion for Special Exceptions, which is an attack on the Kenedy
Foundation's defective paperwork. They sued us but they have delayed
the case by: (1) at the first hearing on this Motion representing
to the court that they would file amended paperwork within 30 days
and not doing so until 98 days later; and (2) harassing the family
by re-suing almost 500 heirs after the deadline to add new parties
to the lawsuit.
The most important part of the hearing is our Motion to Compel and
our Motion for Protection. If you wish to attend you may, but seating
will be very limited.
It is an exciting time for our family because we are finally united
and organized. I would like to ask you to pray for the person whose
hard work has made this all possible, our primo, Hector Cárdenas.
Pray that the Lord continues to guide him and to give him the strength
and wisdom to make the Lord's plan for us a reality.
In the meantime, we are still looking for documents and witness to
help us win the case. If one of your relatives has documents or remembers
anything about La Barreta they should immediately contact myself or
any of the officers of Ballí Family Heritage.
Please continue to pray for justice.
Fred B. Ballí