Amanda Mauricia Younce,“Authorized Representative” for:AMANDA MAURICIA YOUNCEDickinson,Texas Non-domesticSui Juris

NOTICE TO STATE COURT OF REMOVALIN THE JUSTICE COURT PRECINCT 8-1

GALVESTON COUNTY TEXAS

IN REM:

BILICI,HAMDI AND LUTCHMINIA ) PLAINTIFF ) v )

ODELL AMMON BROOM III . ) Case No. E81090253DEFENDANT )

) Odell Ammon Broom III ) Secured Creditor/Third Party Intervenor ) ____________________________________/

NOTICE OF FILING OF NOTICE OF REMOVAL

TO: Clerk of the Justice CourtPrecinct 8-1 GALVESTON COUNTY174 Calder Road, Room 111League City, TX 77573

Mandatory Judicial Notice Rule 201

1) Please take notice that pursuant to 28 U.S.C. §(1331 or 1332) and §1146 and FrCivP Rule 81.1, Odell Ammon Broom III “Third Party Intervenor” did, on the 6th day of October, 2009 file a Notice of Removal in the district court of the United States for the Southern District of Texas, a copy of which is attached hereto, and that said matter shall proceed hereafter in the district court of the United States for the Southern District of Texas. Intervenor acts as Beneficiary, to protect his Security Interest, in the property of the Ens Legis Cestui Que Trust , a.k.a. DEFENDANT.

2) This Court is further noticed that of an automatic stay on proceedings after the notice of removal is filed in state court. See Anthony v. Runyon, 76 F.3d 210, 214 (8th Cir. 1996). The defendant is required to file a copy of the notice of removal with the clerk of the state court “which shall effect the removal and the state court shall proceed no further unless and until the case is remanded.” 28 U.S.C. §1447(d). No order by the federal court is necessary to complete removal. Libhart v. Santa Monica Dairy Co., 592 F.2d

1062 (9th Cir. 1979). The removal is effected automatically by defendantsfiling a notice of removal in the federal court, filing a copy of the notice in thestate court and giving notice to all adverse parties. 28 U.S.C. §1446(e) Once a case has been removed from state court, it is subject to the Federal Rules of Civil Procedure: “These rules apply to civil actions removed . . . from state courts and govern procedureafter removal . . .” F.R.Civ.P. 81(c). See also Willy v. Coastal Corp., 503 U.S. 131, 135-136, 112 S.Ct. 1076, 1079, L.Ed.2d 280 (1992).f.

VERIFICATIONMy Yes means Yes and My No means No before Almighty God.

Done Under Penalties of Perjury without the United States, All Rights Reserved:

Respectfully submitted Dated 6th day of October 2009 A.D.___________________________________________

Odell-Ammon: Broom III, Ambassador and Public Minister

Victim and Federal WitnessBeneficiary andThird Party Intervenor

CERTIFICATE OF SERVICE

I, Odell-Ammon: Broom III, hereby certify that on the 6th day of October 2009 that a copy of the NOTICE OF REMOVAL IN LIMINE and CERTIFICATE OF SERVICE was performed via facsimile and USPS delivered to:

JEANNE BUNNELL LEACH, P.C.Attorney for Plaintiff P.O. Box 980187 Houston, Texas 77098(713) 527-9655(713) 524-5677 FAXBar Card No. 03348500

Clerk of CourtJustice Court Precinct 8-1GALVESTON COUNTY174 Calder Road, Room 111League City, Texas 77573Office: (281) 316-8716Fax: (281) 316-8704:________________________Odell-Ammon: Broom III Ambassador and Public Minister

Victim and Federal WitnessBeneficiary and Third Party Intervenor

Odell Ammon Broom III2100 PecanDickinson,Texas Non-domesticSui Juris

NOTICE OF REMOVAL(DIVERSITY) & (FEDERAL QUESTION)

Case No.3:07-cv-00206ADMIRALTY

In the district court of The United StatesFor the Southern District of Texas

GALVESTON DivisionIN REM:

BILICI,HAMDI AND LUTCHMINIA ) PLAINTIFF ) Schedule (A)v. ) Settlement Phase TWO

ODELL AMMON BROOM III, ) No. PAG-206-002DEFENDANT ) )

Odell Ammon Broom III ) Secured Creditor/Third Party Intervenor ) ____________________________________/

NOTICE OF REMOVAL

TO THE CLERK OF THE ABOVE-ENTITLED COURT:PLEASE TAKE NOTICE that Odell Ammon Broom III “Third Party Intervenor” Herein Intervenor, hereby removes to this Court the state court action described below.IV. On September 23, 2009 , an action was commenced in the Justice Court Precinct 8-1, Galveston County, Texas, entitled HAMDI BILICI and LUTCHMINIA BILICI, Plaintiff, vs.ODELL AMMON BROOM III, Defendant, Case number .E81090253Intervenor, received summons and partial complaint on September 28th, 2009 and received a copy of completed petition on September 30th 2009, This Notice is timely.

VI. A copy of all process, pleadings and orders served upon defendant in the state court action are attached hereto as Exhibit “A”.

VII. This action is a civil action of which this Court has original jurisdiction under 28 U.S.C. §1332, and is one which may be removed to this Court by defendant pursuant to the provisions of 28 U.S.C. §1441(b) in that it is a civil action between citizens of different states and the matter in controversy exceeds the sum of $75,000, exclusive of interest and costs 1) Where Intervenor, tendered to Alamo Title Company thru its

brokers and agents, written instruments exceeding $160,000.00 and 2) Intervenor as (Buyer), accepted Plaintiff’s(Seller) published offer and to secure performance through a Trust Indenture addended to the purchase contract. assumed a portion of sellers liability expressed in the offer.in support of a purchase agreement dated 6/30/2009 and supplemental Trust Indentures for Bailment dated 7/26/2009 and July 31/2009 undertaken by Brokers of Alamo title, attached hereto as Exhibit “B” and “C” for the purchase of real property exceeding160,000.00, and 3) Plaintiff (Seller) complains of non receipt of the funds tendered, and 4) Intervenor (Buyer) while engaging specific performance to the terms of said contract has experienced conduct by the Alamo Title, Brokers which has impaired intervenors ability to perform the obligations of the contract. And 5) Plaintiff’(Sellers) suit could only have been instituted by the Alamo Brokers concealing from Plaintiff (seller)their receipt of funds belonging to Plaintiff (Seller). and 6) Alamo Title Escrow officers have a fiduciary duty to deposit said funds and it is alleged that the escrow officers have endorsed said instruments in violation of the National banking Act,7) Alamo has apparently concealed the existence of the contract and funds from the Plaintiff (Seller) and deprived both Plaintiff (seller) and Intervenor (Buyer) of their right to contract free of impairments. 8) Alamos concealment of funds has deprive the Secretary of Treasury and the government accounting office of revenues due from Alamo’s unjust financial gain. Attached hereto as Exhibit “E”

Diversity of Citizenship Declared by PlaintiffVIII. Intervenor (Buyer) was informed and believes that Plaintiff’(Seller), , was, and still is, a citizen of the State of California. Defendant ODELL AMMON BROOM III was, at the time of the filing of this action, and still is, a citizen of: Texas. These declarations are

Stated on the FACE of Plaintiff’s Original Petition. Attached hereto as Exhibit “F”

The relator herein also identifies the Respondent Superior Alamo Title Parent Corporation (name to be discovered) based in Florida, none of whom are citizens of the same state as plaintiff.(seller)

Federal QuestionThis case is one which may be removed to this Court by defendant pursuant to the provisions of 28 U.S.C. §1441(b) in that it arises under 48 stat 112, HJR192, the National Banking Act, Article 1 Sec 10 US const., Securities and Exchange Act of 1933 and 34. Interfering with interstate commerce. . The proceedings commenced have deprived Intervenor of his First Amendment Right to meaningful access to court in the above number Claim Where through trickery and deceit a Judicial Forum was selected by the attorney for the Plaintiff (Seller) who new or should have known the selected forum was without authority to touch any matter related to Title, or Trusts, and new or should have known that the petition on its face was a material misrepresentation of the subject matter.This petiton was .brought either as an act of incompetence or a deliberate disregard for the rules of proceedure requiring attorneys to make reasonable inquiry that a suit is well grounded in fact or law, and interposed for harrasment or delay. Intervenor alleges that this suit was brought as an act of reprisal for the Intervenors participation in testifying against malfeasant public offcials.XV. There are no other known defendants at this time.

.WHEREFORE, Intervenor moves this court to agree that this action be removed to the district court for the United States Southern District of Texas

DATED: ,October 6th 2009 By ____________________________

Odell-Ammon: Broom III, Ambassador and Public Minister

Victim and Federal WitnessBeneficiary/Third Party Intervenor

Attorneys for Defendant

Comes now: Odell Ammon Broom III, one of the people of and domiciled at the republic state of Texas, an Ambassador and Public Minister on temporary missionary service to the Church of Christ, appears by special visitation, and not generally, as an aggrieved party and a member of the class of victims and federal witnesses and would show the court as follows:

Statement of Facts Supporting Removal

Federal Question

Diversity of Citizenship

Amount in Controversy

1) The aforementioned letter having the legal effect of a summons does not identify if Mr. SIMS is being summonsed in the capacity of, a) Federal Witness, or b) a Victim, c) as a criminal investigator, or in his capacity as d) special prosecutor, Private Attorney General pursuant to 42 USC Sec 1988, or e) in his sovereign capacity as Ambassador and Public Minister.

2) The summons further fails to disclose any Nature or Cause for the associated case and identified proceeding. 3) The Notice letter employed as summons fails to disclose the existence of any

complaint or information and the existence of witnesses, testimony or evidence of record that would be discoverable by Mr. SIMS to enable him to comply with, or cooperate with the unstated purpose of the Notice.

4) The Notice fails to disclose whether Mr. SIMS appearance will waive any of substantial rights, procedural rights, or administrative rights.

5) The Notice fails to disclose the existence of any waivers executed by Mr. SIMS that would evidence of his having executed any knowingly, intentionally, waiver of any of his rights with the advice of counsel.

6) The Notice further fails to show how Mr. SIMS can comply without breaching his fiduciary duty to protect the Victims from further retaliation his privileged imposed upon him in his Private Attorney General capacity prosecuting claims on behalf of the class of victims which includes sexually assaulted minor children, and federal witnesses, to other crimes now in progress in Galveston County.

7) The Notice fails to show why it should not be construed as a fraudulent presentment,And entered into evidence as a confession judgment of intent to interfere, intimidate threaten or otherwise, prevent the testimony of victims and witnesses to federal crime from coming forward.

Summary

Based on the foregoing failures to disclose and in the interest of protecting the class victims, particularly, the Sexually Assaulted Minor Children, not inconsistent with the doctrine of comity, pursuant to Fed.R.Civ.P Rule 45 (d) (2) (B), This Notice of Removal

in Limine of; case number, 257315 docketed in GALVESTON COUNTY COURT #2, is removed to the Federal district court of the united States, Galveston Division “In The Admiralty, case Number 3:07-cv-00206 “

Mandatory Judicial Notice/Cognizance Pursuant To F.R.E. 201

This Court is respectfully asked to take mandatory notice under rule 201 FRE of the following Statutes, Acts of Congress, US Supreme Court Holdings and the applicable Constitutional/Treaty provisions affecting substantial rights.Accused files this notice of removal by and through his Next Friend, Odell-Ammon Broom III, under authority of (a) STATUTES: 28 U.S.C. § 1441- §1447 and 28 U.S.C. §1331, §1333, 18 U.S.C. § 7, § 3231; 46 U.S.C. § 740, § 742, § 781. (b) ACTS OF CONGRESS the Federal Removal Act. The Brady Act, the Miller Act, the Jones Act, the Public Vessels Act, the Sovereign immunities Act, and pursuant to the authorities of (c) US SUPREME COURT HOLDINGS, on” Concealment of Evidence”, found at Brady v. Maryland 373 U.S. 83 (1963), Giglio v. United States. 405 U.S. 150 (1972), United States V. Bagley, 473 U.S. 667 (1985), Kyles v. Whitley, 514 U.S. 419 (1995), Arizona v. Youngblood, 488 U.S. 51 (1988), California v. Trombetta, 467 U.S. 479(1984); (d) US SUPREME COURT HOLDINGS on “Lack of Jurisdiction “Solem v. Bartlett 465 U.S. 463 (1984), United States v. Johnson 457 U.S. 537 (1982), Bousley v. United States, 523 U.S. 614 (1998), Ex Parte McCardle, 74 U.S. 506 (1868).(e) Substantive Rights secured by, Fourth, Fifth, Sixth, Seventh, Eight Ninth and Fourteenth Amendments to The Constitution/Treaty of The United States of America

A. Introduction

1. PLAINTIFF is the STATE OF TEXAS, a.k.a. a corporation; a statutory creature. The ACCUSED is JABRON JACOB SIMS a.k.a. an entity, or fiction of law.

2. On or about July 10th 2008 A.D. the STATE OF TEXAS , by and through the GALVESTON County District Attorneys office did order Next Friend Broom under threat of prolonged judicial process and imprisonment to execute a contract with the District Attorneys office but refused to disclose the provisions of said demands.

3. The PLAINTIFF’S actions leading to the threats occurred on land easements and are properly within the jurisdiction of this Court4. This case became removable on month, day, and year arraigned. See brief in support of motion below.

B. Basis for Removal

5. Removal is proper because ACCUSED suit involves a federal question. Vindicating rights secured by the Fourth, Fifth, Sixth, Eight Ninth and Fourteenth Amendments to The Constitution of The United States of America and the common law authority of Miranda v. Arizona, 384 U.S. 436 (1966). Where rights are reserved and protected by the Constitution, there can be no rule making or legislation in abrogation thereof. The GALVESTON COUNTY District Attorneys office seeks to impair and/or enjoin ACCUSED privilege against self-incrimination by forcing accused to submit to a

proceeding where no indictment based on probable cause has been presented to any authority, usurping the authority of the entire body of Congressional acts, see: Mandatory Judicial Notice above.

6. There may be other similarly situated injured parties in this instant case.

7. The GALVESTON COUNTY District Attorneys office has been unresponsive in producing the disclosures pleadings, process, orders, and other documents relevant to this case.8. ACCUSED will promptly file a copy of this notice of removal with the Clerk of the STATE COURT where orders for imprisonment are in progress, and Warrants for the Arrest of the ACCUSED have been threatened to prevent testimony from being heard.

Brief in Support 9. The proceedings against ACCUSED have deprived him of First Amendment Right to meaningful access to court in the above number Claim precipitating the need for this court’s acceptance of this removal instanter to avoid irreparable harm to ACCUSED and remove Next Friend from the present immediate physical jeopardy composing a law and having it apply retroactively in direct contravention of United States Supreme Court authority – See Stoger v. California, 123 S.Ct. 2446 (U.S. 06/26/2003).

Foreign Venue Authorities

10. Pursuant to the authority of Cook v. State, No. 0375-94 (Tex.Crim.App. 06/28/1995)the STATE OF TEXAS by and through its agents/Officer’s have failed to make a presentment of any charging instrument that allege the elements required to charge an offence. An indictment serves a jurisdictional function. Labelle v. State, 720 S.W.2d 101, 106 (Tex.Cr.App. 1986); Thompson v. State, 697 S.W.2d 413, 415 (Tex.Cr.App. 1985); and, Drumm v. State, 560 S.W.2d 944, 946-947 (Tex.Cr.App. 1977).BREACH OF OATH11. The Ambassador and Public Minister Broom had a reasonable expectation to believe that a valid charging instrument had be produced, and had an expectation to believe that the Officers and Agents of the DISTRICT ATTORNEY had a sworn “contractual duty” to act in good faith, and in accordance with the principles of fair dealing, and clean hands. Jurisdiction vests only upon the filing of a valid indictment in the appropriate court, Tex.Const. Art. V, Section(s) 12(b). See also, Crawford v. State, 624 S.W.2d 906, 907 (Tex.Cr.App. 1981); and, Garcia v. Dial, 596 S.W.2d 524, 527 (Tex.Cr.App. 1980).

Breach of Fiduciary Duty12. Ambassador Broom is domiciled at the republic state of Texas and has acted with a reasonable expectation of Public Trust that the Officer’s of said SHERIFF’S were bound by their “Oath of Office Contract” and would perform, to the provisions of their “Oath of Office Contract” upholding the confidence and trust placed in public officials by the people, via the Constitution of the Texas republic and the connecting treaty provisions found within the Federal Constitution, to know the law, obey the law and uphold all Texas State law and federal laws, especially the laws pertaining to transportation and

interstate commerce.Deceptive Business Practice

13. The COUNTY OF GALVESTON by and through its agent/officer DISTRICT ATTORNEY has engaged in deceptive business practices by making false presentments to Ambassador Broom, statements and instruments known to contain misleading information, calculated to interfere and impair the contractual obligation and duty owed by Ambassador Broom to ACCUSED. That Ambassador Broom was deprived of his God given unalienable rights of property and liberty by conspiring agents/officers of the DISTRICT ATTORNEY. That Ambassador Broom was deceived into believing the above referenced presentment were “constitutionally valid charging instruments” and representations. Prior to 1985, courts have consistently held that "substantive" defects in the charging instrument failed to vest the trial court with jurisdiction and, therefore, a conviction on a substantively defective charging instrument could be challenged for the first time on appeal. Studer, 799 S.W.2d at 267; Thompson, 697 S.W.2d at 415; Green v. State, 571 S.W.2d 13, 14-15 (Tex.Cr.App. 1978); Ex parte Garcia, 544 S.W.2d 432, 432-433 (Tex.Cr.App. 1976); American Plant Food Corp. v. State, 508 S.W.2d 598, 603 (Tex.Cr.App. 1974); Popishel v. State, 255 S.W. 738 (Tex.Cr.App. 1923); and, Woodward v. State, 218 S.W. 760 (Tex.Cr.App. 1920). This rule developed over more than a century of decisions in which we interpreted art. I, Section(s) 10 to create a "constitutional" requirement that a charging instrument allege all elements of the offense in order to constitute an indictment. See Brasfield v. State, 600 S.W.2d 288, 301-302 (Tex.Cr.App. 1980) (Op. on rehg); and, Williams v. The State, 12 Tex.App. 395, 400-401 (Court of Appeals 1882). See also, George E. Dix, Texas Charging Instrument Law: The 1985 Revisions and the Continuing Need for Reform, 38 Baylor L. Rev. 1, at 13-22 (1986). Accordingly, where the charging instrument omitted an element of the offense, the indictment was void and the trial court lacked jurisdiction.

Diversity of Citizenship - A Federal Question14. The failure to disclose any statute allegedly violated or production of “any” charging instrument, deprives ACCUSED of any means to verify that the legal duty imposed upon him is not in violation of God’s Law, and not, pre-empted by, or in violation of federal law. To Wit: An appellate court has the power to correct and reform a trial court judgment "to make the record speak the truth when it has the necessary data and information to do so, or make any appropriate order as the law and nature of the case may require." Nolan v. State, 39 S.W.3d 697, 698 (Tex. App.-Houston [1st Dist.] 2001, no pet.).

Deprivation of Rights15) Ambassador Sims has been denied means to know the nature and cause of the accusations against ACCUSED which in due course of law deprives the STATE OF TEXAS, County DISTRICT ATTORNEY’S Office /GALVESTON County and its adjuncts, of jurisdiction, Self v. State, 709 S.W.2d 662, 666 (Tex. Crim. App. 1986) (citing Brown v. Illinois, 422 U.S.590, 604-05 (1975)). This four-part test assures "that the State cannot violate the Fourth Amendment with impunity by washing its hands in the procedural waters of the Fifth Amendment." Bell v. State, 724 S.W.2d 780, 787 (Tex.

Crim. App. 1986).

FraudC. Conclusion

17. With the above premises considered, the ACCUSED seeks to have this action heard before the U.S. district court as a class member under the Fourth, Fifth, Sixth, Eight Ninth and Fourteenth Amendments to The Constitution of The United States of America so federal questions are properly addressed and Class member’s rights are protected. Federal Question under the constitution, Art. 3, Sec. 2 gives the District Court original jurisdiction of all Admiralty Maritime claims.  Pursuant to Rule 9(a), and STATE actions where jurisdiction was lacking or civil rights were violated.

Case No.3:07-cv-00206ADMIRALTY

In the district court of The United StatesFor the Southern District of Texas

GALVESTON Division

STATE OF TEXAS §§ Deceptive Business Practice§ Witness Tampering

v. § Trial Preparation Material§ Removed Case,

JABRON JACOB SIMS, § 257315§

___________________________________ /ORDER

THE COURT, HAVING REVIEWED THE FACTS AND THE RECORD, FINDS THAT For good cause appearing, It is hereby Ordered that case number 257315 set for hearing at 0830; July 21st 2008, THE COURT having received Notice of Removal in Limine and having satisfied by the presents, moves Sua Sponte to protect the children and class victims and witnesses from further harm. The Clerk is ORDERED to proceed to issue direction to the GALVESTON COUNTY, County Court #2 in case # 257315, to release jurisdiction and deliver the case to THIS COURT without delay. It is Further ORDERED that Supplemental Proceedings of discovery for claim settlement and evidence of damages shall continue subject to disbursement schedules and approval of the Secretary of Treasury of the United States verification and release of deposits previously made and filed into the record of the United State District Court on March 24th 2008. It is Further ORDERED, that all Bills and claims against the accounts upon release of the Secretary shall be disbursed in accordance with the schedule of Disbursement made available at that time. IT IS Further ORDERED that immediate return requirements set forth in Rule 45 (d) (2) (B), and Declared Subject to the claim of Privilege and Protection provisions of Rule 45 (d) (2) (B), trial-preparation material. IT IS SO ORDERED

FURTHER THIS AFFIANT SAYETH NOT.

My Yes means Yes and My No means No before Almighty God. Done Under Penalties of Perjury without the United States, All Rights Reserved:

WITNESS: the SEAL of THE COURT this ____ day of July 2008.

THE COURT

_____________________________________________________________ Odell-Ammon: Broom III, Ambassador and Public Minister for Jesus ChristPrivate Attorney GeneralVICTIM AND FEDERAL WITNESS

PRAECIPE FOR SPECIAL APPEARANCE

TO: Michael Milby, Clerk of the Court district court of the united States Southern District of Texas Galveston, Division Galveston, Texas July 18th 2008

PLEASE ENTER THE ATTACHED ORDER GRANTING THE NOTICE of REMOVAL IN LIMINE AND ISSUE THE ORDER TO COUNTY COURT #2, TO FORWARD THEIR CASE FILES FOR INCLUSION IN THIS CASE.

Case Number: 257315 COUNTY COURT #2 GALVESTON COUNTY

Please date stamp, docket and return confirmation of receipt to

APPOINTING AUTHORITY: Odell-Ammon: Broom III, Private Attorney General

I WILL REPRESENT: by Congressional Authority 42 USC Sec. 1988

ATTORNEY NAME: Pursuant to Sec. 35 of The Judiciary Act of 1789, 1 Stat. 73

SPECIAL COUNSEL: 42 USC Sec. 1988

____________________________________

____________________________________

____________________________________

ATTORNEY’S PHONE NO.: on FILE

ATTORNEY’S FAX NO.: N/A

ATTORNEY’S SIGNATURE: __________________________________ Odell-Ammon: Broom III, Private Attorney General Ambassador, Public Minister, Victim and Federal Witness

PRAECIPE FOR SPECIAL APPEARANCE

TO: Mary Ann Diagle Clerk of the Court Galveston County Court #2 GALVESTON COUNTY, TEXAS 600 59TH Street Galveston, Texas 77551-4137 July 18th 2008

PLEASE PREPARE CASE # 257315 SEE ATTACHED NOTICE of REMOVAL IN LIMINE FOR DELIVERY TO FEDERAL COURT. Case Number: 257315 COUNTY COURT #2 GALVESTON COUNTY Verify docket sheet, list of evidence and all other materials ready for transport to federal court.SEND ALL BILLS OF COSTS TO CLERK OF COURT

Charge the Account # 3:07-CV-00206 Bond pending Treasury Approval

Please date stamp, docket and return confirmation of receipt to

APPOINTING AUTHORITY: Odell-Ammon: Broom III, Private Attorney General I WILL REPRESENT: by Congressional Authority 42 USC Sec. 1988

ATTORNEY NAME: Pursuant to Sec. 35 of The Judiciary Act of 1789, 1 Stat. 73

SPECIAL COUNSEL: ____________________________________

____________________________________

____________________________________

ATTORNEY’S PHONE NO.: on FILE

ATTORNEY’S FAX NO.: N/A

ATTORNEY’S SIGNATURE: __________________________________ Odell-Ammon: Broom III, Private Attorney General Ambassador, Public Minister, Victim and Federal Witness