February 2, 2003
State Bar of Texas
Office of Chief Disciplinary Council
1111 Fannin, Suite 1370
Houston, Texas 77002 Fax:
(713) 752-2158
Robert J.
Killeen, Jr.
8 Greenway Plaza,
Suite 614
Houston, TX 77046
Texas Bar No.
11407000
To Whom It May Concern:
Please consider this our formal complaint against Robert J. Killeen, Jr.
My husband and I are pro se defendants in a frivolous
lawsuit filed against us by Mr. Killeen. We can and will prove to a jury that
this lawsuit is groundless and was brought for the purpose of harassment.
In attempts to run roughshod over us, Mr. Killeen repeatedly
violates the intent and purposes of the law. He repeatedly violates the Texas
Rules of Civil Procedure and case law, and he repeatedly fails to extend even
simple courtesy. If you are interested in many more details than I include in
this letter, you can read them on my web site at http://dottie.clickhere2.net/chronology.html.
At this time, I am addressing two main complaints to the
Bar:
(1) After answering discovery requests, my husband discovered that he had inadvertently provided some privileged documents. After three requests to Mr. Killeen to return those documents pursuant to Rule 193.3(d) of the Texas Rules of Civil Procedure, he finally complied. Said rule specifies the return of any copies as well. At our depositions on January 30th, Mr. Killeen questioned my husband about – and entered as an Exhibit – a copy of one of those privileged documents
Mr. Killeen also entered as an Exhibit in that deposition a page from my husband’s medical record that had been released to him by his physician client without the consent of my husband. Mr. Killeen should have advised his client that medical records are privileged.
(2) When
I declined to provide my social security number to Mr. Killeen in deposition,
he became overbearing and abusive and implied that he was authorized
under the Texas Rules of Civil
Procedure to obtain my social security number. (I knew better.) While I’m sure that anyone can ask
for someone’s social security number, few people are actually authorized under
law to obtain it. For Mr. Killeen to imply that he has that authority, and for
him to try to bully someone into furnishing it, is a breach of ethics at the
very least. (The deposition was videotaped, so we will have concrete proof of
Mr. Killeen’s abusive behavior.)
At the conclusion of this lawsuit, we will address the
myriad ways in which Mr. Killeen not only has repeatedly violated the rules for
professional conduct, but he has also violated the Texas Rules of Civil
Procedure.
In the meantime, I will appreciate your response regarding
how you intend to deal with my complaints in (1) and (2) above.
Sincerely,
Dottie Harrison
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