Preview
Electronically Filed
8/1/2017 2:55 PM
Hidalgo County District Clerks
Reviewed By: Andria Garcia
CAUSE NO. C-6851-13-C
JOSE A. SOLIS § IN THE DISTRICT COURT
§
§
V. § HIDALGO COUNTY, TEXAS
§
VIPERS BASKETBALL, LLC §
D/B/A RIO GRANDE VALLEY VIPERS § 139TH JUDICIAL DISTRICT
PLAINTIFF’S FIRST AMENDED ORIGINAL PETITION
WITH JURY DEMAND AND REQUEST FOR DISCLOSURE
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, JOSE A. SOLIS, Plaintiff in the above entitled and numbered
cause, complaining of and against VIPERS BASKETBALL, LLC D/B/A RIO
GRANDE VALLEY VIPERS, Defendant herein, and for causes of action would
respectfully show unto the Court the following:
A. Discovery-Control Plan
1. Pursuant to Rule 190.4 of the Texas Rules of Civil Procedure, Plaintiff requests
a Level 3 discovery control plan.
B. Parties
2. Plaintiff is a resident of Starr County, Texas.
3. Defendant VIPERS BASKETBALL, LLC D/B/A RIO GRANDE VALLEY
VIPERS has appeared and answered herein through counsel.
C. Venue
4. Venue is proper in Hidalgo County, Texas, pursuant to TeX. CiV. Prac. & Rem.
Code §15.002(a), because all or substantial part of the events or omissions occurred in
Hidalgo County, Texas and Defendant, a Limited Liability Company, maintains its
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principal office in Hidalgo County, Texas.
D. Facts
5. On or about January 23, 2013, Plaintiff attended a Vipers Basketball game at
the State Farm Arena in Hidalgo, Texas. For promotional purposes during the
game’s intermission, Defendant held a basketball shooting contest and selected
Plaintiff as the participant. The contest rules—i.e. the terms of the agreement—were
simple and witnessed by thousands of people attending the Vipers Basketball game
that night. Defendants unequivocally promised to give Plaintiff a brand new Seventy-
Five Thousand Dollar ($75,000.00) Jaguar car if Plaintiff successfully made one three-
point basketball goal and one half-court basketball goal all within sixty seconds. It is
undisputed that Plaintiff was successful in making the required three-point shot and
the half-court shot, which was completed within the specified time period of sixty
seconds. Moreover, the entire sequence of events was video recorded and verified by
Defendants. The promotional basketball shooting contest constitutes an offer to enter
into a unilateral contract which Plaintiff accepted. Plaintiff’s successful performance
of each and every action and condition as specified by Defendant constitutes a valid
and enforceable unilateral contract requiring Defendant to perform its end of the
bargain and provide Plaintiff a brand new Seventy-Five Thousand Dollar ($75,000.00)
Jaguar car.
6. Defendant did not perform its obligations under the terms of the unilateral
contract (Basketball Shooting Contest). Thereafter, Plaintiff instituted the case at
bar against Defendant alleging breach of contract and seeking specific performance
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and/or compensatory damages for Defendant’s breach of the unilateral contract
(Basketball Shooting Contest). The parties conducted written discovery and oral
depositions in the case at bar.
7. On or about November 6, 2016, prior to trial, acting through their attorneys,
Plaintiff and Defendant reached a settlement agreement of the underlying breach of
contract claim (Basketball Shooting Contest). Defendant agreed to pay Plaintiff
Thirty Thousand Dollars ($30,000.00), in return for a release of all claims in the
underlying suit and dismissal of the case.
8. As of this filing, many months have passed since the parties reached a
settlement agreement encompassing all claims in the underlying case involving the
dispute over the Basketball Shooting Contest, but Defendant has failed and refused to
comply with any of the essential terms of the parties’ Settlement Agreement. Many
months have passed and Defendant has not paid Plaintiff the Thirty Thousand
Dollars ($30,000.00) Defendant agreed to pay in settlement of the underlying civil
case.
9. Defendant materially breached the terms of the unilateral contract (Basketball
Shooting Contest) by failing to provide the agreed upon consideration/compensation.
Defendant has now materially breached the parties’ settlement agreement negotiated
by the parties through counsel.
E. First Cause of Action—Breach of Contract
(Settlement Agreement of November 6, 2016)
10. Plaintiff incorporates paragraphs 1 through 9 and for First Cause of Action
against Defendant would show that Defendant has materially breached the terms of
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the parties’ Settlement Agreement by failing to pay the Thirty Thousand Dollars
($30,000.00) agreed upon by the parties and their counsel within a reasonable time.
The essential terms of the Settlement Agreement were reduced to writing and agreed
upon by both parties. The Settlement Agreement is valid and enforceable, and there
is exists no justification or excuse for Defendant’s failure to perform its obligations
under the terms of the Settlement Agreement. Defendant’s material breach of the
Settlement Agreement has caused Plaintiff to suffer actual, compensatory damages,
including the expenditure of additional reasonable costs and litigation expenses and
attorneys’ fees, for which Plaintiff seeks recovery herein as stated below.
11. Pleading further, pursuant to the holding in Mantas v. Fifth Court of Appeals,
925 S.W.2d 656 (Tex. 1996), Plaintiff seeks abatement of the underlying cause of
action (alleging breach of the unilateral contract/Basketball Shooting Contest),
pending the Court’s determination of the validity and enforceability of the parties’
November 6, 2016 Settlement Agreement.
F. Second Cause of Action—Breach of Unilateral Contract
(Basketball Shooting Contest of January 23, 2013)
12. Plaintiff would show that on January 23, 2013, Plaintiff and Defendants
entered into a valid and enforceable oral contract that was performable within one
year, and that Plaintiff accepted the unilateral contract from Defendants by his
performance of making the required three-point shot and half-court shot within sixty
seconds.
13. Plaintiff would show that he has performed all contractual obligations.
14. Defendant materially breached the contract by refusing to give Plaintiff the
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promised consideration (i.e. title to the Seventy-Five Thousand Dollar Jaguar car).
15. As a direct and proximate cause of Defendant’s breach of contract Plaintiff has
sustained compensatory damages and loss of use, reliance damages, attorney fees,
and cost and expenses.
G. Third Cause of Action—Common-Law Fraud
16. Pleading further, for third cause of action against Defendant, Plaintiff
incorporates paragraphs 1 through 11 above as if fully set forth herein and would
show that Defendant VIPERS BASKETBALL, LLC D/B/A RIO GRANDE VALLEY
VIPERS, acting through its agents, representatives and/or employees, made
affirmative, explicit representations to Plaintiff.
17. Defendant’s representations to Plaintiff were material and Plaintiff relied on
the representation that he would receive title to a new Seventy-Five-Thousand
Dollar Jaguar car if Plaintiff made the three-point shot and half-court shot within
sixty seconds.
18. Defendant’s representations to Plaintiff were false promises of future
performance and Defendant had no intention of performing said promise. Further,
Defendants’ conduct amounted to a false representation to Plaintiff.
19. Defendant made the false representation knowing it was false.
20. Defendant intended for Plaintiff to rely on the false representation.
21. Plaintiff relied on Defendant’s false representations when Plaintiff
successfully made the one half-court shot and the one three-point shot within the
sixty second timeframe.
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22. Defendant’s false representations were the direct and proximate cause of
Plaintiff’s injuries, which include actual damages, benefit-of—the-bargain damages,
past and future mental anguish, and exemplary damages.
H. Damages
23. As a direct and proximate cause of Defendants’ breach of contract and common-
law fraud, Plaintiff suffered and continues to suffer actual damages, expectancy
damages and loss of use, reliance damages, benefit-of—the—bargain damages,
exemplary damages, past and future mental anguish, attorney fees, and cost and
expenses. As such, Plaintiff, JOSE A. SOLIS, afiirmatively pleads that he seeks
monetary relief over $200,000.00 but not more than $1,000,000.00.
24. Exemplary Damages. Plaintiff’s injury resulted from Defendants’ actual fraud
and/or malice, which entitles Plaintiff to exemplary damages under Tex. Civ. Prac. &
Rem. Code § 41.003(a).
25. Attorney Fees. Plaintiff is entitled to recover reasonable attorney fees under
Tex. CiV. Prac. & Rem. Code § 38.001(8) because this suit is for breach of an oral
contract. Plaintiff retained counsel, who presented Plaintiffs claim to Defendant.
Defendant did not tender the amount owed within 30 days of when the claim was
presented to Defendant.
I. Equitable Relief
26. In the alternative to monetary damages, Plaintiff seeks specific performance
of the contract.
J. Jury Demand
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27. Plaintiff requests a jury trial.
K. Conditions Precedent
28. All conditions precedent to Plaintiff’s claim for relief have been performed or
have occurred.
L. Request For Disclosure
29. Pursuant to Rule 194 of the Texas Rules of Civil Procedure, you are hereby
requested to disclose, within fifty (50) days of service of this document, the
information or material described in the Request for Disclosures below. Please serve
your responses on counsel representing this Plaintiff, and produce true and correct
copies of all documents and other tangible items with your responses, in accordance
with Rule 194.4.
Plaintiff requests disclosure of the following, pursuant to Rules 194.2(a)
through 194.2(l):
(a) the correct names of the parties to the lawsuit;
(b) the name, address, and telephone number of any potential parties;
(c) the legal theories and, in general, the factual bases of Defendant's claims
or defenses;
(d) the amount and any method of calculating economic damages;
(e) the name, address, and telephone number of persons having knowledge
of relevant facts, and a brief statement of each identified person's
connection with the case;
(f) for any testifying expert:
(1) the expert's name, address, and telephone number;
(2) the subject matter on which the expert will testify;
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(3) the general substance of the expert's mental impressions and
opinions and a brief summary of the basis for them, or if the
expert is not retained by, employed by, or otherwise subject to the
control of Defendant, documents reflecting such information;
(4) if the expert is retained by, employed by, or otherwise subject to
the control of Defendant:
(A) all documents, tangible things, reports, models, or data
compilations that have been provided to, reviewed by, or
prepared by or for the expert in anticipation of the expert's
testimony; and
(B) the expert's current resume and bibliography;
(g) any discoverable indemnity and insuring agreements;
(h) any discoverable settlement agreements;
(i) any discoverable witness statements;
(j) in a suit alleging physical or mental injury and damages from the
occurrence that is the subject of the case, all medical records and bills
that are reasonably related to the injuries or damages asserted or, in
lieu thereof, an authorization permitting the disclosure of such medical
records and bills;
(k) in a suit alleging physical or mental injury and damages from the
occurrence that is the subject of the case, all medical records and bills
obtained by the responding party by virtue of an authorization
furnished by the requesting party.
(l) the name, address, and telephone number of any person who may be
designated as a responsible third party.
30. WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that Defendant be
cited to appear and answer herein, and that upon final trial hereof, Plaintiff recover
from said Defendant a sum over $200,000.00 but not more than $1,000,000.00,
actual damages, expectancy damages and loss of use, reliance damages, benefit-of-
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the-bargain damages, exemplary damages, attorney fees, costs of Court, pre-
judgment and post-judgment interest at the legal rate, and/or specific performance of
the contract, and demand for judgment for all other relief whether in law or equity7
general or special, to which the Plaintiff is deemed justly entitled.
Respectfully submitted,
STERN LAW GROUP
/s/ Joseph R. Corteguera
JEFFREY M. STERN
SBN: 19175660
Email: J stern@stern-lawgroup.com
JOSEPH R. CORTEGUERA
SBN: 00787291
Email: J C0rteg‘uera@stern-lawgroup.com
4909 Bissonnet St., Suite 100
Bellaire, Texas 77401
713/661-9900 Telephone
713/666-5922 Facsimile
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE
I hereby certify that on thisday of August, 2017, a true and correct copy of
1St
the foregoing instrument was forwarded to all counsel of record by electronic delivery,
telephonic document transfer, messenger, hand delivery, express delivery, and/or
certified mail, return receipt requested.
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Mr. Gerald Castillo
Gonzalez Castillo, LLP
1317 E. Quebec Ave.
McAllen, Texas 78503
Via E-Mail: GCastillo@valleytzrm.com
ls/ Joseph R. Corteguera
JOSEPH R. CORTEGUERA
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Preview
Electronically Filed 8/1/2017 2:55 PM Hidalgo County District Clerks Reviewed By: Andria Garcia CAUSE NO. C-6851-13-C JOSE A. SOLIS § IN THE DISTRICT COURT § § V. § HIDALGO COUNTY, TEXAS § VIPERS BASKETBALL, LLC § D/B/A RIO GRANDE VALLEY VIPERS § 139TH JUDICIAL DISTRICT PLAINTIFF’S FIRST AMENDED ORIGINAL PETITION WITH JURY DEMAND AND REQUEST FOR DISCLOSURE TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, JOSE A. SOLIS, Plaintiff in the above entitled and numbered cause, complaining of and against VIPERS BASKETBALL, LLC D/B/A RIO GRANDE VALLEY VIPERS, Defendant herein, and for causes of action would respectfully show unto the Court the following: A. Discovery-Control Plan 1. Pursuant to Rule 190.4 of the Texas Rules of Civil Procedure, Plaintiff requests a Level 3 discovery control plan. B. Parties 2. Plaintiff is a resident of Starr County, Texas. 3. Defendant VIPERS BASKETBALL, LLC D/B/A RIO GRANDE VALLEY VIPERS has appeared and answered herein through counsel. C. Venue 4. Venue is proper in Hidalgo County, Texas, pursuant to TeX. CiV. Prac. & Rem. Code §15.002(a), because all or substantial part of the events or omissions occurred in Hidalgo County, Texas and Defendant, a Limited Liability Company, maintains its Page 1 ofll] Electronically Filed 8/1/2017 2:55 PM Hidalgo County District Clerks Reviewed By: Andria Garcia principal office in Hidalgo County, Texas. D. Facts 5. On or about January 23, 2013, Plaintiff attended a Vipers Basketball game at the State Farm Arena in Hidalgo, Texas. For promotional purposes during the game’s intermission, Defendant held a basketball shooting contest and selected Plaintiff as the participant. The contest rules—i.e. the terms of the agreement—were simple and witnessed by thousands of people attending the Vipers Basketball game that night. Defendants unequivocally promised to give Plaintiff a brand new Seventy- Five Thousand Dollar ($75,000.00) Jaguar car if Plaintiff successfully made one three- point basketball goal and one half-court basketball goal all within sixty seconds. It is undisputed that Plaintiff was successful in making the required three-point shot and the half-court shot, which was completed within the specified time period of sixty seconds. Moreover, the entire sequence of events was video recorded and verified by Defendants. The promotional basketball shooting contest constitutes an offer to enter into a unilateral contract which Plaintiff accepted. Plaintiff’s successful performance of each and every action and condition as specified by Defendant constitutes a valid and enforceable unilateral contract requiring Defendant to perform its end of the bargain and provide Plaintiff a brand new Seventy-Five Thousand Dollar ($75,000.00) Jaguar car. 6. Defendant did not perform its obligations under the terms of the unilateral contract (Basketball Shooting Contest). Thereafter, Plaintiff instituted the case at bar against Defendant alleging breach of contract and seeking specific performance Page 2 of 10 Electronically Filed 8/1/2017 2:55 PM Hidalgo County District Clerks Reviewed By: Andria Garcia and/or compensatory damages for Defendant’s breach of the unilateral contract (Basketball Shooting Contest). The parties conducted written discovery and oral depositions in the case at bar. 7. On or about November 6, 2016, prior to trial, acting through their attorneys, Plaintiff and Defendant reached a settlement agreement of the underlying breach of contract claim (Basketball Shooting Contest). Defendant agreed to pay Plaintiff Thirty Thousand Dollars ($30,000.00), in return for a release of all claims in the underlying suit and dismissal of the case. 8. As of this filing, many months have passed since the parties reached a settlement agreement encompassing all claims in the underlying case involving the dispute over the Basketball Shooting Contest, but Defendant has failed and refused to comply with any of the essential terms of the parties’ Settlement Agreement. Many months have passed and Defendant has not paid Plaintiff the Thirty Thousand Dollars ($30,000.00) Defendant agreed to pay in settlement of the underlying civil case. 9. Defendant materially breached the terms of the unilateral contract (Basketball Shooting Contest) by failing to provide the agreed upon consideration/compensation. Defendant has now materially breached the parties’ settlement agreement negotiated by the parties through counsel. E. First Cause of Action—Breach of Contract (Settlement Agreement of November 6, 2016) 10. Plaintiff incorporates paragraphs 1 through 9 and for First Cause of Action against Defendant would show that Defendant has materially breached the terms of Page 3 of 10 Electronically Filed 8/1/2017 2:55 PM Hidalgo County District Clerks Reviewed By: Andria Garcia the parties’ Settlement Agreement by failing to pay the Thirty Thousand Dollars ($30,000.00) agreed upon by the parties and their counsel within a reasonable time. The essential terms of the Settlement Agreement were reduced to writing and agreed upon by both parties. The Settlement Agreement is valid and enforceable, and there is exists no justification or excuse for Defendant’s failure to perform its obligations under the terms of the Settlement Agreement. Defendant’s material breach of the Settlement Agreement has caused Plaintiff to suffer actual, compensatory damages, including the expenditure of additional reasonable costs and litigation expenses and attorneys’ fees, for which Plaintiff seeks recovery herein as stated below. 11. Pleading further, pursuant to the holding in Mantas v. Fifth Court of Appeals, 925 S.W.2d 656 (Tex. 1996), Plaintiff seeks abatement of the underlying cause of action (alleging breach of the unilateral contract/Basketball Shooting Contest), pending the Court’s determination of the validity and enforceability of the parties’ November 6, 2016 Settlement Agreement. F. Second Cause of Action—Breach of Unilateral Contract (Basketball Shooting Contest of January 23, 2013) 12. Plaintiff would show that on January 23, 2013, Plaintiff and Defendants entered into a valid and enforceable oral contract that was performable within one year, and that Plaintiff accepted the unilateral contract from Defendants by his performance of making the required three-point shot and half-court shot within sixty seconds. 13. Plaintiff would show that he has performed all contractual obligations. 14. Defendant materially breached the contract by refusing to give Plaintiff the Page 4 of 10 Electronically Filed 8/1/2017 2:55 PM Hidalgo County District Clerks Reviewed By: Andria Garcia promised consideration (i.e. title to the Seventy-Five Thousand Dollar Jaguar car). 15. As a direct and proximate cause of Defendant’s breach of contract Plaintiff has sustained compensatory damages and loss of use, reliance damages, attorney fees, and cost and expenses. G. Third Cause of Action—Common-Law Fraud 16. Pleading further, for third cause of action against Defendant, Plaintiff incorporates paragraphs 1 through 11 above as if fully set forth herein and would show that Defendant VIPERS BASKETBALL, LLC D/B/A RIO GRANDE VALLEY VIPERS, acting through its agents, representatives and/or employees, made affirmative, explicit representations to Plaintiff. 17. Defendant’s representations to Plaintiff were material and Plaintiff relied on the representation that he would receive title to a new Seventy-Five-Thousand Dollar Jaguar car if Plaintiff made the three-point shot and half-court shot within sixty seconds. 18. Defendant’s representations to Plaintiff were false promises of future performance and Defendant had no intention of performing said promise. Further, Defendants’ conduct amounted to a false representation to Plaintiff. 19. Defendant made the false representation knowing it was false. 20. Defendant intended for Plaintiff to rely on the false representation. 21. Plaintiff relied on Defendant’s false representations when Plaintiff successfully made the one half-court shot and the one three-point shot within the sixty second timeframe. Page 5 of 10 Electronically Filed 8/1/2017 2:55 PM Hidalgo County District Clerks Reviewed By: Andria Garcia 22. Defendant’s false representations were the direct and proximate cause of Plaintiff’s injuries, which include actual damages, benefit-of—the-bargain damages, past and future mental anguish, and exemplary damages. H. Damages 23. As a direct and proximate cause of Defendants’ breach of contract and common- law fraud, Plaintiff suffered and continues to suffer actual damages, expectancy damages and loss of use, reliance damages, benefit-of—the—bargain damages, exemplary damages, past and future mental anguish, attorney fees, and cost and expenses. As such, Plaintiff, JOSE A. SOLIS, afiirmatively pleads that he seeks monetary relief over $200,000.00 but not more than $1,000,000.00. 24. Exemplary Damages. Plaintiff’s injury resulted from Defendants’ actual fraud and/or malice, which entitles Plaintiff to exemplary damages under Tex. Civ. Prac. & Rem. Code § 41.003(a). 25. Attorney Fees. Plaintiff is entitled to recover reasonable attorney fees under Tex. CiV. Prac. & Rem. Code § 38.001(8) because this suit is for breach of an oral contract. Plaintiff retained counsel, who presented Plaintiffs claim to Defendant. Defendant did not tender the amount owed within 30 days of when the claim was presented to Defendant. I. Equitable Relief 26. In the alternative to monetary damages, Plaintiff seeks specific performance of the contract. J. Jury Demand Page 6 of 10 Electronically Filed 8/1/2017 2:55 PM Hidalgo County District Clerks Reviewed By: Andria Garcia 27. Plaintiff requests a jury trial. K. Conditions Precedent 28. All conditions precedent to Plaintiff’s claim for relief have been performed or have occurred. L. Request For Disclosure 29. Pursuant to Rule 194 of the Texas Rules of Civil Procedure, you are hereby requested to disclose, within fifty (50) days of service of this document, the information or material described in the Request for Disclosures below. Please serve your responses on counsel representing this Plaintiff, and produce true and correct copies of all documents and other tangible items with your responses, in accordance with Rule 194.4. Plaintiff requests disclosure of the following, pursuant to Rules 194.2(a) through 194.2(l): (a) the correct names of the parties to the lawsuit; (b) the name, address, and telephone number of any potential parties; (c) the legal theories and, in general, the factual bases of Defendant's claims or defenses; (d) the amount and any method of calculating economic damages; (e) the name, address, and telephone number of persons having knowledge of relevant facts, and a brief statement of each identified person's connection with the case; (f) for any testifying expert: (1) the expert's name, address, and telephone number; (2) the subject matter on which the expert will testify; Page 7 of 10 Electronically Filed 8/1/2017 2:55 PM Hidalgo County District Clerks Reviewed By: Andria Garcia (3) the general substance of the expert's mental impressions and opinions and a brief summary of the basis for them, or if the expert is not retained by, employed by, or otherwise subject to the control of Defendant, documents reflecting such information; (4) if the expert is retained by, employed by, or otherwise subject to the control of Defendant: (A) all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert's testimony; and (B) the expert's current resume and bibliography; (g) any discoverable indemnity and insuring agreements; (h) any discoverable settlement agreements; (i) any discoverable witness statements; (j) in a suit alleging physical or mental injury and damages from the occurrence that is the subject of the case, all medical records and bills that are reasonably related to the injuries or damages asserted or, in lieu thereof, an authorization permitting the disclosure of such medical records and bills; (k) in a suit alleging physical or mental injury and damages from the occurrence that is the subject of the case, all medical records and bills obtained by the responding party by virtue of an authorization furnished by the requesting party. (l) the name, address, and telephone number of any person who may be designated as a responsible third party. 30. WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that Defendant be cited to appear and answer herein, and that upon final trial hereof, Plaintiff recover from said Defendant a sum over $200,000.00 but not more than $1,000,000.00, actual damages, expectancy damages and loss of use, reliance damages, benefit-of- Page 8 of 10 Electronically Filed 8/1/2017 2:55 PM Hidalgo County District Clerks Reviewed By: Andria Garcia the-bargain damages, exemplary damages, attorney fees, costs of Court, pre- judgment and post-judgment interest at the legal rate, and/or specific performance of the contract, and demand for judgment for all other relief whether in law or equity7 general or special, to which the Plaintiff is deemed justly entitled. Respectfully submitted, STERN LAW GROUP /s/ Joseph R. Corteguera JEFFREY M. STERN SBN: 19175660 Email: J stern@stern-lawgroup.com JOSEPH R. CORTEGUERA SBN: 00787291 Email: J C0rteg‘uera@stern-lawgroup.com 4909 Bissonnet St., Suite 100 Bellaire, Texas 77401 713/661-9900 Telephone 713/666-5922 Facsimile ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE I hereby certify that on thisday of August, 2017, a true and correct copy of 1St the foregoing instrument was forwarded to all counsel of record by electronic delivery, telephonic document transfer, messenger, hand delivery, express delivery, and/or certified mail, return receipt requested. Page 9 0f 10 Electronically Filed 8/1/2017 2:55 PM Hidalgo County District Clerks Reviewed By: Andria Garcia Mr. Gerald Castillo Gonzalez Castillo, LLP 1317 E. Quebec Ave. McAllen, Texas 78503 Via E-Mail: GCastillo@valleytzrm.com ls/ Joseph R. Corteguera JOSEPH R. CORTEGUERA Page 10 0f 10