Preview
FILED
TARRANT COUNTY
4/6/2021 2:21 PM
THOMAS A. WILDER
017-324510-21 DISTRICT CLERK
NO. _____________________
RHONDA TALDO § IN THE DISTRICT COURT
§
V. § ______ JUDICIAL DISTRICT
§
DAVID TALDO § TARRANT COUNTY, TEXAS
PETITION TO ENFORCE FOREIGN JUDGMENT
This Petition to Enforce Foreign Judgment and the attached foreign judgment and
affidavit are filed under the Uniform Enforcement of Foreign Judgments Act, chapter 35 of the
Texas Civil Practice and Remedies Code, by Rhonda Taldo, Petitioner. The last three numbers
of Petitioner's driver's license number are 227. The last three numbers of Petitioner's Social
Security number are 928.
1. Discovery in this case is intended to be conducted under level 2 of rule 190 of the
Texas Rules of Civil Procedure.
2. A properly authenticated copy of the Judgment rendered July 8, 2019 is attached
as Exhibit A and is entitled to full faith and credit.
2. A properly authenticated copy of the Consent Judgment is attached as Exhibit B
rendered March 13, 2019 and is entitled to full faith and credit.
3. The Judgment and Consent Judgment are final and not subject to modification.
4. Respondent, David Taldo, has refused to pay spousal maintenance, and Petitioner
seeks enforcement.
Petitioner prays that this judgment of the First Judicial District Court in Caddo Parish of
the state of Louisiana be accorded full faith and credit and have the same effect as a judgment of
this Court.
PETITION TO ENFORCE FOREIGN JUDGMENT 1
Respectfully submitted,
G J CHAVEZ & ASSOCIATES, PC
1100 E. Campbell Road, Suite 240
Richardson, TX 75081
Tel: (972) 705-5374
Fax: (972) 705-5105
By:/s/ Benjamin Perez Jr.
Benjamin Perez Jr.
State Bar No. 24085817
bperez@gjclaw.com
Attorney for Petitioner
PETITION TO ENFORCE FOREIGN JUDGMENT 2
NO. ________________
RHONDA T ALDO § IN THE DISTRICT COURT
§
V. § .JUDICIAL DISTRICT
§
DAVIDTALDO § TARRANT COUNTY, TEXAS
SUPPORTING AFFIDAVIT
Benjamin Perez Jr. appeared in person before me today and stated under oath:
" I. My name is Benjamin Perez Jr.. Iam above the age of eighteen years, and I am
full y competent to make thi s affidavit. The facts stated in this affidavit are witrun my personal
knowledge and are true and correct. I am the attorney for the petitioner in this civil action which
is the basis for the foreig n judgment sought to be enforced by this peti tion.
"2. The last known post office address of David Taldo is 67 17 S FORK DR, NORTH
RIC HLAND H ILLS, TX 76182-4473.
"3. The address of Rhonda Taldo is 4222 STONE CREEK DR, LIBERTY TWP, OH
4501 1-5440.
"4.
Sui te 240, Richardson, TX 75081."
Benjamin Perez Jr.
Attorney fo r Petitioner
SIGNED under oath before me on MarcM ls-"1 10~ I
,,,,,,~~~''' HEIDY AGU IN
....' "-~· ···
......
§f(..~~/t:~ Notery Public, State of Texas
~"{··.~;k~fComm Exp~res 04- 10-2023
,,,;'f,:r;,,,,,. -
Notary 1013196 7754
PETITION TO ENFORCE FOREIGN JUDGMENT 3
PLACED IN MINUTEs
.. •
.· ~
DAVIDTALDO
VERSUS . FIRST JUDIClAL DISTRICT COURT
RHONDA TALDO * CADDO PARlSH, LOUISIANA
JUDGMENT
THIS CA1JSE having come on regularly for argument on Motion to Compel
Discovery, both parties represented by counsel of record, evidence adduced by the
stipulation of the parties, the law and evidence being i.n favor thereof for reasons this day
orally assigned:
IT IS ORDERED, ADJUDGED.AND DECREED that as a supplemental
partition herein, DAVID TALDO shall pay RHONDA TALDO the sum of THREE
THOUSAND&N0/100 ($a,ooo.oo)DOLLARSwiththecontractualspousalsupport
payment due RHONDA TALDO on July 1, 2019 which will make the total swn to be paid
to RHONDA TALDO the amount of $5,250.00. In exchange for that payment, RHONDA
Exhibit A
TALDO waives any further claim to any balance in the accol,llt in the name of DAVID
TALDO in the Thompson Pipe Group Retirement Plan.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that this
compromise is further dispositive of any and.all further claims between the parties with
regard to the various retirement accounts inventoried in the Judgment of Partition
rendered March 13, 2019.
ITISFURTHER.ORDERED,ADJUDGEDANDDECREEDthatDAVID
TALDO shall present· a specific inventory of the personal property items which he was
scheduled to receive in the division of the corporeal movable property set forth in the
Judgment of Partition and to the extent RHONDA TALDO has possession of any of those
. items, she will cooperate with DAVID TALDO for the return of those personal items.
JUDGMENT ~~ on the 27th zof June, 2019 in Shreveport,
Caddo Parish, Louisiana.· I ~ :t:MAIL~ N/J _
I INDEX REC_FAX_
W/0 DOC CERT MAIL
SERVICE -
(1)
..} .,
.•.
"'I
..
·'.
c
_ JUDGMENT READ, SIGNED AND FILED on the __:::::_ day of
'- )l~ \'1
PREPARED BY: APPROVED AS TO FORM AND
CONTENT:
BOOTII LOCKARD POLITZ & LeSAGE, HENRY GOODRICH, JR.
L.L.C.
920 Pierremont Road, Suite 104 614 Ashboume Drive
Shreveport, Louisiana 71106 Shreveport, Louisiana 71106
Telephone: 318-222-2333 Telephone: 318-347-7151
Facsimile: 318-221-1035 Facsimile: 318-670-8581
ATTORNEY FOR RHONDA TALDO ATTORNEY FOR DAVID TALDO
-----·--- ·--·-·-·--.......- ...
•·
PLACED IN MINUTES
DAVIDTALDO * NUMBER 609,545-D
VERSUS *· FIRST JUDICIAL DISTRICI' COURT
·RHONDATALDO * CADDO PARISH, LOUISIANA
CONSENT JUDGMENT
'
THIS CAUSE having come on regularly for trial as a consent matter on the ~;:
e·.
Supplemental Reconventional Demand filed by RHONDA TALDO, both parties present and •l::·
represented by counsel of record; evidence adduced by testimony and stipulation of the c
>
parties, the law and evidence bei~ in favor the_reof for reasons this day orally assigned:
ITISORDERED,ADJUDGEDANDDECREEDthataJudgmentoffinal <::
·~.::
·~::
divorce, a vi"nculo matrimonii, is entered pursuant to the provisions of La. Civ. Code Art. .;;:
J··:
103(1) between the parties hereto dissolving the bonds of matrimony heretofore existing 4i'
•1::
between DAVID TALDO and RHONDA TALDO.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that
pursuanttostipulationoftbepartiesDAVIDTALDOwillpayRHONDATALDOcontractual
Exhibit B
spousal support in the amount of 1WO THOUSAND 1WO JJUNDJmD FIFI'Y &
. N0/100 ($2,250.00) DOllARS per month for thirty-six (36) months. Said sum shall
be payable in one payment on the first day of each month and the first day of each
succeeding month for the thirty-six (36) month term effective immediately. Said
contractual spousal support shall be non-modifiable and non-terminable except upon one
of the following:
(1) The death of either party;
(2) Remarriage by Rhonda Taldo;
(3) Rhonda Tal do's cohabitation in the manner of married persons
as defined by Louisiana law; and
(4) Expiration/satisfaction of the paymentterm.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that
pursuant to stipulation RHONDA TALDO waives any and all claims for interim periodic
spousal support and final periodic spousal support as part and parcel of the agreement for
contractual spousal support set forth hereinabove.
FILED
.'GS S }~- '1LN V (1)
. ~~
CC ~ l'
Ji;
...
: '·
~~
VA disability benefits being received by DAVID TALDO are his separate property.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that with .;:·
~·i'
(.:·
the exception of obligations set forth herein, the parties hereto do hereby fully acquit, ,:::
·····
release, discharge, and relieve each other from any and all other claims, however incurred, r·••,
whatsoever of any nature or kind by their own separate estates or the matrimonial regime
of the community of acquets and gains with regard to the division of community property
between RHONDA TALDO and DAVID TALDO and further, this Judgment of Partition is
dispositive as to all claims regarding community property between the partieS. It is the
intention of the parties hereto to lay at rest forever, finally and for all future purposes, any
and all claims, including reimbursement and rental Claims, that they had, do have or may
have against each other arising out of or during their marriage with respect to the use,
disposition, sale or transfer of community property or any of their separate funds or
property or the use of their community property funds on or affecting same, whether same
was by purchase, improvements or otherwise. Further, the parties reciprocally waive all
reimbursements claims due either party, including all claims by either party's separate
estate against the separate estate of the other party, the separate estate of either party
against the parties in community and by the parties in community against the separate
estate of either party.
IT IS FURTHEROR,DERED,ADJUDGEDAND DECREED that each
of the parties does hereby assert and affirm that they have revealed unto each other all
of the properties, assets and indebtednesses necessary to make a full and final settlement
of their respective disputes against each other and there shall be no further accounting by
eith.er party to the other with regard to their separate estates and/or the community
property regime and vice versa.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that the f··
r·
parties convey all of their right, title and interest in and to all of the apove described r--.
property to each other as set forth at length hereinabove, acknowledging that same is being ~::
done with full and adequate consideration with each party recognizing as having been
received from the other.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that both
.;t:-
··.
parties are directed to sign any and all notes, mortgages, transfers, bills of sale, acts of "':
·~=:
J·--
donation, deeds or other instruments necessary to carry out the intents and purposes of this ····.
Partition Judgment as required by them or any third parties. Either party shall be entitled
to specific enforcement of each and every provision of this partition judgment which
specific performance may be sought and enforced by summary process. In the event
specific performance is necessary, the defaulting party shall be liable to ·the other for
damages due to the delay or inconvenience caused by the defaulting party's recalcitrance
as well as reasonable attorney's fees, interest and costs, all of which may also be enforced
by summary process, any objection thereto being waived. The obligations of both parties
herein shall be deemed to be heritable obligations.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that it is
understood arid agreed that any promises of the parties herein to pay any indebtedness
enumerated in this property settlement are not to be interpreted so that this Judgment of
Partition might be subject to either an expressed or implied resolutory condition, it being
especially understood and agreed that either party may alienate, mortgage or
otherwise encumber all or any portion of the property acquired by him or her in this
Judgment of Partition. In connection therewith, the parties hereto hereby declare that it
is their intent to especially waive the benefit of any expressed or implied resolutory
condition or any expressed or implied vendor's lien, it being stipulated and agreed that the
(5)
..
obligations to paythe indebtednesses as set forth in saidJudgmentofPartition are personal
obligations only ·and each party, for the consideration herein received, especiilllywarrants
that third parties may .deal With either of the parties hereto free and clear of any
expressed or implied resolutory condition or any expressed or implied vendor's lien.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that all r· •.
other matters pending between these parties are hereby merged into this Consent Judgment ~;:_
(::·
and resolved. I~'.
~t:
JUDG~ RENDERED, READ AND SIGNED on the \3:. dayof :i;,
1;:..:
1;;::
('/\ o.-r ~
J.r....ao19 in Shreveport, Caddo Parish,. Louisiana. ~~:
..
·~
_ _.._nON. KAREUAR. STEWART
DISTRICI' JUDGE- SECI'ION D
PREPARED BY: APPROVED AS TO FORM AND
CONTENT:
BOOTH LOCKARD POLITZ & LeSAGE; HENRY GOODRICH, JR.
L.L.C.
920 Pierremont Road, Suite 104 614Ashbourne Drive
Shreveport, Louisiana 71106 Shreveport, Louisiana 71106
Telephone: 318-222-2333 Telephone: 318-347-7151
Facsimile: 318-221-1035 Facsimile: 318-670-8581
ATIORNEY FOR RHONDA TALDO
(6)
NO
FIRST JUDICIAL DISTRICT COURT
OF LOUISIANA, IN AND FOR
STATE OF LOUISIANA THE PARISH OF CADDO
PARISH OF CADDO
I, Mike Spence, Recorder of Caddo Parish, Louisiana, and Clerk of the First Judicial District Court
of the State of Louisiana, in and for the Parish of Caddo, do hereby certifY and attest the foregoing to be a
full and correct copy of the original.
DAVID TALDO VERSUS RHONDA TALDO - SUIT NUMBER 609,545-D
JUDGMENT FILED JULY 1, 2019 AND CONSENT JUDGMENT FILED
MARCH 13, 2019 IN THE CIVIL RECORDS OF CADDO PARISH,
LOUISIANA.
on file or of record in my office, and that I have carefully compared the same with the original.
In Witness Whereof, I have hereunto set my hand and annexed the Seal of
The First Judicial District Court of the State of Louisiana, Parish of Caddo.
STATE OF LOUISIANA
PARISH OF CADDO
I, Ramona Emanuel, Judge of the First Judicial District Court of the State of Louisiana, Parish of
Caddo, do hereby certifY that Mike Spence is Recorder of Caddo Parish, Louisiana, and Clerk of the First
Judicial District Court of the State of Louisiana, Parish of Caddo (which Court is a court of record, having
a seal); that the signature to the foregoing certificate and attestation is the genuine signature of the said
Mike Spence as such officer; that the seal annexed thereto is the seal of said First Judicial District Court of
the State of Louisiana, Parish of Caddo; that said Mike Spence, as such Clerk and recorder, is the legal
custodian of the original records or documents described and referred to in the foregoing certificate, is the
proper officer to execute the said certificate and attestation, and such attestation is in due form according
to the laws of the State of Louisiana.
In Witness Whereof, I have hereunto set my hand in my official character as
Judge, at the City of Shreveport, Parish of Caddo, State of Louisiana.
STATE OF LOUISIANA
PARISH OF CADDO
I, Mike Spence, Recorder of Caddo Parish, State of Louisiana, and Clerk of the First Judicial
District Court of the State of Louisiana, Parish of Caddo (which court is a court of record, having a seal
which is annexed hereto), do hereby certifY that Ramona Emanuel, whose name is subscribed to the
foregoing certificate of due attestation was, at the time of signing the same, Judge of the First Judicial
District Court of the State of Louisiana, Parish of Caddo, and was duly commissioned, qualified and
authorized by law to execute said certificate. And I do further certifY that the signature of the Judge above
named to the said certificate of due attestation is genuine.
In Witness Whereof, I have hereunto set my hand and annexed the Seal of
the First Judicial District Court of the State of Louisiana, Parish of Caddo.
MARC '
~
2 21
s
Mike Spence, Recorder Caddo Parish Louisiana
and Clerk of the First Judicial District Court of the State of Louisiana, Parish of Caddo
Preview
FILED TARRANT COUNTY 4/6/2021 2:21 PM THOMAS A. WILDER 017-324510-21 DISTRICT CLERK NO. _____________________ RHONDA TALDO § IN THE DISTRICT COURT § V. § ______ JUDICIAL DISTRICT § DAVID TALDO § TARRANT COUNTY, TEXAS PETITION TO ENFORCE FOREIGN JUDGMENT This Petition to Enforce Foreign Judgment and the attached foreign judgment and affidavit are filed under the Uniform Enforcement of Foreign Judgments Act, chapter 35 of the Texas Civil Practice and Remedies Code, by Rhonda Taldo, Petitioner. The last three numbers of Petitioner's driver's license number are 227. The last three numbers of Petitioner's Social Security number are 928. 1. Discovery in this case is intended to be conducted under level 2 of rule 190 of the Texas Rules of Civil Procedure. 2. A properly authenticated copy of the Judgment rendered July 8, 2019 is attached as Exhibit A and is entitled to full faith and credit. 2. A properly authenticated copy of the Consent Judgment is attached as Exhibit B rendered March 13, 2019 and is entitled to full faith and credit. 3. The Judgment and Consent Judgment are final and not subject to modification. 4. Respondent, David Taldo, has refused to pay spousal maintenance, and Petitioner seeks enforcement. Petitioner prays that this judgment of the First Judicial District Court in Caddo Parish of the state of Louisiana be accorded full faith and credit and have the same effect as a judgment of this Court. PETITION TO ENFORCE FOREIGN JUDGMENT 1 Respectfully submitted, G J CHAVEZ & ASSOCIATES, PC 1100 E. Campbell Road, Suite 240 Richardson, TX 75081 Tel: (972) 705-5374 Fax: (972) 705-5105 By:/s/ Benjamin Perez Jr. Benjamin Perez Jr. State Bar No. 24085817 bperez@gjclaw.com Attorney for Petitioner PETITION TO ENFORCE FOREIGN JUDGMENT 2 NO. ________________ RHONDA T ALDO § IN THE DISTRICT COURT § V. § .JUDICIAL DISTRICT § DAVIDTALDO § TARRANT COUNTY, TEXAS SUPPORTING AFFIDAVIT Benjamin Perez Jr. appeared in person before me today and stated under oath: " I. My name is Benjamin Perez Jr.. Iam above the age of eighteen years, and I am full y competent to make thi s affidavit. The facts stated in this affidavit are witrun my personal knowledge and are true and correct. I am the attorney for the petitioner in this civil action which is the basis for the foreig n judgment sought to be enforced by this peti tion. "2. The last known post office address of David Taldo is 67 17 S FORK DR, NORTH RIC HLAND H ILLS, TX 76182-4473. "3. The address of Rhonda Taldo is 4222 STONE CREEK DR, LIBERTY TWP, OH 4501 1-5440. "4. Sui te 240, Richardson, TX 75081." Benjamin Perez Jr. Attorney fo r Petitioner SIGNED under oath before me on MarcM ls-"1 10~ I ,,,,,,~~~''' HEIDY AGU IN ....' "-~· ··· ...... §f(..~~/t:~ Notery Public, State of Texas ~"{··.~;k~fComm Exp~res 04- 10-2023 ,,,;'f,:r;,,,,,. - Notary 1013196 7754 PETITION TO ENFORCE FOREIGN JUDGMENT 3 PLACED IN MINUTEs .. • .· ~ DAVIDTALDO VERSUS . FIRST JUDIClAL DISTRICT COURT RHONDA TALDO * CADDO PARlSH, LOUISIANA JUDGMENT THIS CA1JSE having come on regularly for argument on Motion to Compel Discovery, both parties represented by counsel of record, evidence adduced by the stipulation of the parties, the law and evidence being i.n favor thereof for reasons this day orally assigned: IT IS ORDERED, ADJUDGED.AND DECREED that as a supplemental partition herein, DAVID TALDO shall pay RHONDA TALDO the sum of THREE THOUSAND&N0/100 ($a,ooo.oo)DOLLARSwiththecontractualspousalsupport payment due RHONDA TALDO on July 1, 2019 which will make the total swn to be paid to RHONDA TALDO the amount of $5,250.00. In exchange for that payment, RHONDA Exhibit A TALDO waives any further claim to any balance in the accol,llt in the name of DAVID TALDO in the Thompson Pipe Group Retirement Plan. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that this compromise is further dispositive of any and.all further claims between the parties with regard to the various retirement accounts inventoried in the Judgment of Partition rendered March 13, 2019. ITISFURTHER.ORDERED,ADJUDGEDANDDECREEDthatDAVID TALDO shall present· a specific inventory of the personal property items which he was scheduled to receive in the division of the corporeal movable property set forth in the Judgment of Partition and to the extent RHONDA TALDO has possession of any of those . items, she will cooperate with DAVID TALDO for the return of those personal items. JUDGMENT ~~ on the 27th zof June, 2019 in Shreveport, Caddo Parish, Louisiana.· I ~ :t:MAIL~ N/J _ I INDEX REC_FAX_ W/0 DOC CERT MAIL SERVICE - (1) ..} ., .•. "'I .. ·'. c _ JUDGMENT READ, SIGNED AND FILED on the __:::::_ day of '- )l~ \'1 PREPARED BY: APPROVED AS TO FORM AND CONTENT: BOOTII LOCKARD POLITZ & LeSAGE, HENRY GOODRICH, JR. L.L.C. 920 Pierremont Road, Suite 104 614 Ashboume Drive Shreveport, Louisiana 71106 Shreveport, Louisiana 71106 Telephone: 318-222-2333 Telephone: 318-347-7151 Facsimile: 318-221-1035 Facsimile: 318-670-8581 ATTORNEY FOR RHONDA TALDO ATTORNEY FOR DAVID TALDO -----·--- ·--·-·-·--.......- ... •· PLACED IN MINUTES DAVIDTALDO * NUMBER 609,545-D VERSUS *· FIRST JUDICIAL DISTRICI' COURT ·RHONDATALDO * CADDO PARISH, LOUISIANA CONSENT JUDGMENT ' THIS CAUSE having come on regularly for trial as a consent matter on the ~;: e·. Supplemental Reconventional Demand filed by RHONDA TALDO, both parties present and •l::· represented by counsel of record; evidence adduced by testimony and stipulation of the c > parties, the law and evidence bei~ in favor the_reof for reasons this day orally assigned: ITISORDERED,ADJUDGEDANDDECREEDthataJudgmentoffinal <:: ·~.:: ·~:: divorce, a vi"nculo matrimonii, is entered pursuant to the provisions of La. Civ. Code Art. .;;: J··: 103(1) between the parties hereto dissolving the bonds of matrimony heretofore existing 4i' •1:: between DAVID TALDO and RHONDA TALDO. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that pursuanttostipulationoftbepartiesDAVIDTALDOwillpayRHONDATALDOcontractual Exhibit B spousal support in the amount of 1WO THOUSAND 1WO JJUNDJmD FIFI'Y & . N0/100 ($2,250.00) DOllARS per month for thirty-six (36) months. Said sum shall be payable in one payment on the first day of each month and the first day of each succeeding month for the thirty-six (36) month term effective immediately. Said contractual spousal support shall be non-modifiable and non-terminable except upon one of the following: (1) The death of either party; (2) Remarriage by Rhonda Taldo; (3) Rhonda Tal do's cohabitation in the manner of married persons as defined by Louisiana law; and (4) Expiration/satisfaction of the paymentterm. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that pursuant to stipulation RHONDA TALDO waives any and all claims for interim periodic spousal support and final periodic spousal support as part and parcel of the agreement for contractual spousal support set forth hereinabove. FILED .'GS S }~- '1LN V (1) . ~~ CC ~ l' Ji; ... : '· ~~ VA disability benefits being received by DAVID TALDO are his separate property. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that with .;:· ~·i' (.:· the exception of obligations set forth herein, the parties hereto do hereby fully acquit, ,::: ····· release, discharge, and relieve each other from any and all other claims, however incurred, r·••, whatsoever of any nature or kind by their own separate estates or the matrimonial regime of the community of acquets and gains with regard to the division of community property between RHONDA TALDO and DAVID TALDO and further, this Judgment of Partition is dispositive as to all claims regarding community property between the partieS. It is the intention of the parties hereto to lay at rest forever, finally and for all future purposes, any and all claims, including reimbursement and rental Claims, that they had, do have or may have against each other arising out of or during their marriage with respect to the use, disposition, sale or transfer of community property or any of their separate funds or property or the use of their community property funds on or affecting same, whether same was by purchase, improvements or otherwise. Further, the parties reciprocally waive all reimbursements claims due either party, including all claims by either party's separate estate against the separate estate of the other party, the separate estate of either party against the parties in community and by the parties in community against the separate estate of either party. IT IS FURTHEROR,DERED,ADJUDGEDAND DECREED that each of the parties does hereby assert and affirm that they have revealed unto each other all of the properties, assets and indebtednesses necessary to make a full and final settlement of their respective disputes against each other and there shall be no further accounting by eith.er party to the other with regard to their separate estates and/or the community property regime and vice versa. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that the f·· r· parties convey all of their right, title and interest in and to all of the apove described r--. property to each other as set forth at length hereinabove, acknowledging that same is being ~:: done with full and adequate consideration with each party recognizing as having been received from the other. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that both .;t:- ··. parties are directed to sign any and all notes, mortgages, transfers, bills of sale, acts of "': ·~=: J·-- donation, deeds or other instruments necessary to carry out the intents and purposes of this ····. Partition Judgment as required by them or any third parties. Either party shall be entitled to specific enforcement of each and every provision of this partition judgment which specific performance may be sought and enforced by summary process. In the event specific performance is necessary, the defaulting party shall be liable to ·the other for damages due to the delay or inconvenience caused by the defaulting party's recalcitrance as well as reasonable attorney's fees, interest and costs, all of which may also be enforced by summary process, any objection thereto being waived. The obligations of both parties herein shall be deemed to be heritable obligations. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that it is understood arid agreed that any promises of the parties herein to pay any indebtedness enumerated in this property settlement are not to be interpreted so that this Judgment of Partition might be subject to either an expressed or implied resolutory condition, it being especially understood and agreed that either party may alienate, mortgage or otherwise encumber all or any portion of the property acquired by him or her in this Judgment of Partition. In connection therewith, the parties hereto hereby declare that it is their intent to especially waive the benefit of any expressed or implied resolutory condition or any expressed or implied vendor's lien, it being stipulated and agreed that the (5) .. obligations to paythe indebtednesses as set forth in saidJudgmentofPartition are personal obligations only ·and each party, for the consideration herein received, especiilllywarrants that third parties may .deal With either of the parties hereto free and clear of any expressed or implied resolutory condition or any expressed or implied vendor's lien. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that all r· •. other matters pending between these parties are hereby merged into this Consent Judgment ~;:_ (::· and resolved. I~'. ~t: JUDG~ RENDERED, READ AND SIGNED on the \3:. dayof :i;, 1;:..: 1;;:: ('/\ o.-r ~ J.r....ao19 in Shreveport, Caddo Parish,. Louisiana. ~~: .. ·~ _ _.._nON. KAREUAR. STEWART DISTRICI' JUDGE- SECI'ION D PREPARED BY: APPROVED AS TO FORM AND CONTENT: BOOTH LOCKARD POLITZ & LeSAGE; HENRY GOODRICH, JR. L.L.C. 920 Pierremont Road, Suite 104 614Ashbourne Drive Shreveport, Louisiana 71106 Shreveport, Louisiana 71106 Telephone: 318-222-2333 Telephone: 318-347-7151 Facsimile: 318-221-1035 Facsimile: 318-670-8581 ATIORNEY FOR RHONDA TALDO (6) NO FIRST JUDICIAL DISTRICT COURT OF LOUISIANA, IN AND FOR STATE OF LOUISIANA THE PARISH OF CADDO PARISH OF CADDO I, Mike Spence, Recorder of Caddo Parish, Louisiana, and Clerk of the First Judicial District Court of the State of Louisiana, in and for the Parish of Caddo, do hereby certifY and attest the foregoing to be a full and correct copy of the original. DAVID TALDO VERSUS RHONDA TALDO - SUIT NUMBER 609,545-D JUDGMENT FILED JULY 1, 2019 AND CONSENT JUDGMENT FILED MARCH 13, 2019 IN THE CIVIL RECORDS OF CADDO PARISH, LOUISIANA. on file or of record in my office, and that I have carefully compared the same with the original. In Witness Whereof, I have hereunto set my hand and annexed the Seal of The First Judicial District Court of the State of Louisiana, Parish of Caddo. STATE OF LOUISIANA PARISH OF CADDO I, Ramona Emanuel, Judge of the First Judicial District Court of the State of Louisiana, Parish of Caddo, do hereby certifY that Mike Spence is Recorder of Caddo Parish, Louisiana, and Clerk of the First Judicial District Court of the State of Louisiana, Parish of Caddo (which Court is a court of record, having a seal); that the signature to the foregoing certificate and attestation is the genuine signature of the said Mike Spence as such officer; that the seal annexed thereto is the seal of said First Judicial District Court of the State of Louisiana, Parish of Caddo; that said Mike Spence, as such Clerk and recorder, is the legal custodian of the original records or documents described and referred to in the foregoing certificate, is the proper officer to execute the said certificate and attestation, and such attestation is in due form according to the laws of the State of Louisiana. In Witness Whereof, I have hereunto set my hand in my official character as Judge, at the City of Shreveport, Parish of Caddo, State of Louisiana. STATE OF LOUISIANA PARISH OF CADDO I, Mike Spence, Recorder of Caddo Parish, State of Louisiana, and Clerk of the First Judicial District Court of the State of Louisiana, Parish of Caddo (which court is a court of record, having a seal which is annexed hereto), do hereby certifY that Ramona Emanuel, whose name is subscribed to the foregoing certificate of due attestation was, at the time of signing the same, Judge of the First Judicial District Court of the State of Louisiana, Parish of Caddo, and was duly commissioned, qualified and authorized by law to execute said certificate. And I do further certifY that the signature of the Judge above named to the said certificate of due attestation is genuine. In Witness Whereof, I have hereunto set my hand and annexed the Seal of the First Judicial District Court of the State of Louisiana, Parish of Caddo. MARC ' ~ 2 21 s Mike Spence, Recorder Caddo Parish Louisiana and Clerk of the First Judicial District Court of the State of Louisiana, Parish of Caddo