Teague - Supreme Court of Texas

STA'IXmNT OF THE FACTS
At the outset of its brief, Petitioner, the City of ~aclrsboro (herehfk referred to
as the "City 3
') states that the "relevant facts of this case are not really in dispute."
Petitiumr 's Brief at 1. To the contrary, there seem to be a fundamental disagreement
regding what constitutes the relevant facts in the current matter. ARer its initial
assertion, the City proceeds to inundate the Court with aver six (6) pages of evidentiary
assertions in a case which has never reached the evidentiary stage. In f'act, most of the
City's factual assertions are disputed and are based upon conclusion and speculation and
have never been offered under the Texas Rules of Evidence in any adversarial
proceeding. Respondent, Perry Teague (hereinafter referred to as "Teague") has as yet,
never had the oppodmity to object to, cross-examine, challenge or investigate the
veracity of any of the city's assertions. (CR at 4). In fact, Teague's extensive efforts in
this litigation are almost entirely focused on his effort to obtain the opportunity to
challenge and object to the one-sided allegations of the City. Teagw could easily provide
his own fbtual assertions regarding the status of his home (the property at issue), the
alleged illegal actions of the City and its agents, or any other number of unsubstantiated
allegations in response. However to do so only serves to &tract hm the true issues
before the Court.
The only relevant facts relate to the procedural histury of this matter and their
relation to jurisdictional issues. The relevant jurisdidd facts are as follows: