D-1-GN-17-006662 Electronically FiledC-3360-18-C

10/10/2018 3:25 PM
Hidalgo County District Clerks
Reviewed By: Iris Ramirez

V E R IF Y | S

STATE
OF
DELAWARE

”00-proffl
 Electronically Filed
10/10/2018 3:25 PM
Hidalgo County District Clerks
Reviewed By: Iris Ramirez

want of prosecution

Verifyis  Foundation  a  tax  exempt  entity  located  in  Delaware  will  now  Bring  Forth  the  forms  of  
action  for  a  given  cause  D-­‐1-­‐GN-­‐17-­‐006662  per  C-­‐3360-­‐18-­‐C  
 Electronically Filed
9/6/2018
10/10/201812:45
3:25PMPM
Hidalgo County District Clerks
Reviewed By: Alexis Bonilla
Iris Ramirez

C-3360-18-C
No._______________________________

RYAN M. FROST † § IN THE STATE COURT

§
§ A
§
v. § ____
139th JUDICIAL DISTRICT
§
§ !
§
EDWARD CICCONE § HIDALGO COUNTY, TEXAS
and THE LAW OFFICES OF ° °
EZEQUIEL REYNA

LINDSEY WHISENHANT

PLAINTIFF’S ORIGINAL PETITION

Plaintiff, R. M. FROST, files this original petition against said defendants and alleges as
follows

DISCOVERY-CONTROL PLAN

1. Plaintiff intends to conduct discovery under Level 2 of Texas Rule of Civil Procedure
190.3 and affirmatively pleads that this suit is not governed by the expedited-actions process
in Texas Rule of Civil Procedure 169 because plaintiff requests injunctive relief and seeks
monetary relief of $1,181,939.68

CLASS ZERO SET OF FORMS FOR AN ACTIONABLE CAUSE

!! Pursuant to His wishes, The Applicant will speak in first person after filing a
master case in Travis County District Court D-1-GN-17-006662 12/13/17.
Any move to dismiss under 91a will result in the revocation of a Texas License
through the Disciplinary Council of State Bar and may conceive further litigation.

CLAIM FOR RELIEF

2. Plaintiff seeks monetary relief of $1,181,939.68 including damages of any kind,

penalties, court costs, expenses and prejudgment interest, and attorney fees.
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10/10/2018 3:25 PM
Hidalgo County District Clerks
Reviewed By: Iris Ramirez

PARTIES

3. Plaintiff, R. M. FROST, is an individual residing in Bexar County at 7426 Dove

Mountain, San Antonio, TX 78209

4. Defendant, EDWARD CICCONE and THE LAW OFFICES OF EZEQUIEL REYNA

an individual and taxable entity may be served with process at defendant’s usual place of
business in Hidalgo County at 702 W Expy 83 # 100, Weslaco, TX 78596

5. Defendant, LINDSEY WHINSEHANT an individual may be served with process at

defendant’s usual place of business in Tyler County at 130 S Charlton Street, Woodville, TX
75979

VENUE

6. Venue is mandatory in Hidalgo County under Texas Civil Practice & Remedies Code
section 15.017 because this suit involved criminal acts, and The Looting of a Decedent
Estate. This is the location of Stolen Monies.

FACTS

7.

•! Edward Ciccone is The Serial Killer

•! Ezequiel Reyna is Mafioso

•! Lindsey Whisenhant is a Loser

•! Together they stole My Family’s Money after Mother and Grandfather both
died in 2014

•! They have had Four Years and Forty-Eight Months to bring My Capital

•! Set me up to look mentally ill by testifying at a commitment hearing with a

local police department in Lakeway, TX that occurred 9/15/15

•! Coerced and inveigled me to move into The Wrong Building

•! Contributed to the Death of My Cat Zulu and The Vandalism of My Jaguar XJ

2015 that was captured on security cameras which is available for viewing on
YouTube handle ‘Frosyn aRt’

•! Forced me to Do Everything On My Own

•! Caused Massive Legal Expenditures and Incredible Torment

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10/10/2018 3:25 PM
Hidalgo County District Clerks
Reviewed By: Iris Ramirez

•! Is withholding me from seeing Medical Specialist James Vardaman Kemper

who did My Cochlear Implant in 2010 and affixed a BAHA device

•! I’m having trouble sleeping every night with blood coming out of my surgery
and The Fear of What Will Be Done To Me

•! People come off the street to death threat me where I’m being held

•! Mr. Ciccone will not carry out his fiduciary duty by helping to take care of a
rundown property he stuck me in

•! He allows documents to sit at the Probate Court for many months until everyone
forgets about them Except Me

•! I have tried multiple times to get into contact with his colleague Ezequiel Reyna
only to realize he is Just As Bad

•! Lindsey Whisenhant will not respond to my phone calls or emails and he is the
de facto probate attorney for Mother and Grandfather in Woodville, TX

•! It was necessary to hire yet another attorney Philip Martin Ross who charges
high wages at $500/hr

•! The Executor and Administrator respectively is attempting to send me checks in

the mail for $6000 that I Want To Stop.

•! I am a direct beneficiary of Mother (Clarica A. Pernoud) and even written out in

Grandfather’s (Rene B. Pernoud) Last Will & Testament

•! Edward Ciccone has tried to hide his illegal activity by collateralizing two
different estates into one and pretending there are not any Written Documents to go
Off Of

•! There is plenty of resources to see that I, RYAN MICHAEL FROST born

RYAN MICHAEL RENE PERNOUD am the Lawful Heir

COUNT 1

MISSAPPLICATION OF FUNDS BY A FIDUCIARY

Texas PENAL § 32.45

JURY DEMAND

8. Plaintiff demands jury trial and tenders appropriate fee with this petition
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10/10/2018 3:25 PM
Hidalgo County District Clerks
Reviewed By: Iris Ramirez

CONDITIONS PRECEDENT

9. All conditions precedent to Plaintiff’s claim for relief have been performed or have
occurred.

REQUEST OF DISCLOSURE

10. Under Texas Rule of Civil Procedure 194, Plaintiff requests that defendant disclose
within 50 days of the service of this request, the information or material described in 194.2

OBJECTION TO ASSOCIATE JUDGE

11. Plaintiff objects to the referral of this case to an associate judge for hearing a trial on
the merits or presiding at a jury trial.

PRAYER

12. For these reasons, Plaintiff asks that the court issue citation for defendant to appear and
answer, and that Plaintiff be awarded a judgment against defendant for the following

a. Actual damages

b. $1,181,939.68

c. Exemplary damages

d. Prejudgment and post-judgment interest

e. Court costs

f. Attorney fees

g. All other relief to which the plaintiff is entitled

By:________________
RYAN M. FROST
7426 Dove Mountain
San Antonio, TX 78209
512-964-6835
 Electronically Filed
10/10/2018 3:25 PM
Hidalgo County District Clerks
Reviewed By: Iris Ramirez

Defendant(s):
702 W Expy 83 # 100
Weslaco, TX 78596

130 S Charlton Street

Woodville, TX 75979

Plaintiff:
7426 Dove Mountain
San Antonio, TX 78209