Preview
Filed: 8/2/2022 1:01 PM
1 citation to be issued. Assigned to MM J OHN D. KINARD - District Clerk
Galveston County, Texas
LINEBARGER GOGGAN BLAIR & SAMPSON, LLP. Envelope No. 66886282
ATTORNEYS AT LAW By: Monique McNeal
8/2/2022 2:02 PM
518 - 9th Avenue North (77590)
P. O. Box 2789
Texas City, TX 77592-2789
——-- +
(409) 948-3401
(409) 945-9814 - FAX
August 02, 2022
J ohn D. Kinard
District Clerk, Galveston County
600 59th St Ste 4001
Galveston, TX 77551-2388
Please note: This citation will be served by a
private process server. Please do not assess
the service fee for this citation.
RE: SUIT NO. 21-TX-0357, GALVESTON COUNTY, ET AL VS. EVANGELINA HERNANDEZ
GUZMAN, IN THE 56™ J UDICIAL DISTRICT COURT OF GALVESTON COUNTY, TEXAS
Dear Mr. Kinard:
Enclosed please find the following document(s):
¥__ Citation(s)to be Re-Issued. Please re-issue the enclosed citation(s). Upon issuance,
please forward the issued citation(s) to our office via email in the customary manner. Thank you for
your assistance and if anyone concerned has any questions, please feel free to contact our office.
Sincerely,
Apo CW i
Mark E. Ciavaglia
Attorney at Law
MEC\nlv
Enclosure
THE STATE OF TEXAS
SUIT NO. 21-TX-0357
FOR QUESTIONS CONCERNING THIS LAWSUIT, PLEASE
CONTACT THE LAW FIRM OF LINEBARGER GOGGAN
STATE OF TEXAS BLAIR & SAMPSON, LLP AS SHOWN BELOW. TO REQUEST
COUNTY OF GALVESTON A PAYOFF OF THIS LAWSUIT, PLEASE FAX A WRITTEN
REQUEST TO (409) 945-9814OR EMAIL A REQUEST TO:
PAY OFF.GALVESTONCOUNTY @LGBS.COM. PLEASE
REFERENCE THE SUIT NUMBER IN YOUR REQUEST.
TO: Evangelina Hernandez Guzman
1416 Y upon St.
La Marque, TX 77568-4240
GREETING: YOU HAVE BEEN SUED. You may employ an attorney. If you or your attomey do not file a
written answer with the clerk who issued this citation by 10:00 a.m. on the Monday next after the
expiration of 20 days after you were served this citation, a default judgment may be taken against
you. In addition to filing a written answer with the clerk, you may be required to make initial
disclosures to other parties of this suit. These disclosures generally must be made no later than 30
days after you file your answer with the clerk. Find out more at TexasLawHelp.org.
YOU ARE HEREBY COMMANDED to appear and answer, by filing a written answer, before the
Honorable District Court, 56th Judicial District, Galveston County, Texas, at 600 59th St Ste 4001, Galveston,
TX 77551-2388 at or before 10 o’clock a.m. of the Monday next after the expiration of 20 days from the date of
service of this Citation, then and there to answer the Original Petition of the TEXAS CITY INDEPENDENT
SCHOOL DISTRICT, Plaintiffs, filed in the said Court on the 23rd day of June, 2021, against Evangelina
Hernandez Guzman, Defendant(s).
The nature of the suit is a demand to collect delinquent ad valorem taxes, penalties, interest, attorney's
fees, court costs and $500.00 in abstractor's fees incurred on the following property:
PROPERTY DESCRIPTION
Tract 1: Acct. No. 397700000005001 (197220); All that certain tract or parcel of land situated in Galveston
County, Texas in the John D. Moore League, in the Townsite formerly known as HIGHLAND CITY, now known
as La Marque, being part of the Northeast quarter of Block No. Five (5) and being more particularly described by
metes & bounds at File No. 2019038538 in the Office of the Clerk of Galveston County, Texas.
Tract 2: Acct. No. 397700000005017 (197245); All that certain tract or parcel of land situated in Galveston
County, Texas in the John D. Moore League, in the Townsite formerly known as HIGHLAND CITY, now known
as La Marque, being part of the North one-fourth (1/4) of Lot No. Five (5) and being more particularly described
by metes & bounds at File No. 2017042460 in the Office of the Clerk of Galveston County, Texas.
The Amount of taxes due Plaintiff(s), inclusive of interest and penalties if paid in:
JURISDICTION August 2022 September 2022
Texas City Independent School District $2,451.96 $2,468.44
The names of all taxing units which assess and collect taxes on said property, not made parties to the suit,
are: GALVESTON COUNTY; CITY OF LA MARQUE; GALVESTON COUNTY DRAINAGE DISTRICT #
02 and COLLEGE OF THE MAINLAND. The foregoing taxing units, if any be shown, are made and joined as
parties to this suit and invited to add their claim by intervening herein. There are no taxing units which assess
and collect taxes on said property that Plaintiff(s) has failed to join as a party to this suit.
Plaintiff(s), and all other taxing units who may set up their tax claims herein seek recovery of delinquent
ad valorem taxes on the property and in addition to the taxes, all interest, penalties, attorney's fees, abstractor's
fees and court costs allowed by law up to and including the day of judgment, post judgment interest at the
maximum rate allowed by law and the establishment and foreclosure of liens securing the payment of same, as
provided by law.
All parties to this suit shall take notice that claims not only for any taxes which were delinquent on the
property at the time this suit was filed but all taxes becoming delinquent at any time thereafter up to the day of
judgment, including all interest, penalties, attorney's fees, and costs allowed by law may be recovered without
further citation or notice to any parties and all parties shall take notice of and plead and answer to all claims and
pleadings now on file and which may be filed in this cause by all other parties and by all of those taxing units
above named, who may intervene and set up their tax claims against the property.
THE OFFICER OR OTHER AUTHORIZED PERSON EXECUTING THIS RETURN SHALL
PROMPTLY SERVE THE SAME ACCORDING TO THE REQUIREMENTS OF LAW AND THE
MANDATES HEREOF AND MAKE DUE RETURN AS THE LAW DIRECTS.
ISSUED BUT NOT PREPARED BY DISTRICT CLERK’S OFFICE AND GIVEN UNDER MY
HANDAND SEAL OF THE COURT AT GALVESTON, TEXAS, this the —--- day of
-- ea , 20 ——
LINEBARGER GOGGAN JOHN D. KINARD
BLAIR & SAMPSON, LLP CLERK OF THE DISTRICT COURTS
518 - 9th Avenue North (77590) OF GALVESTON COUNTY, TEXAS
PO Box 2789 600 59TH ST STE 4001
Texas City, TX 77592-2789 GALVESTON, TX 77551-2388
(409) 948-3401
(409) 945-9814 - FAX
By: ----
ATTORNEY FOR PLAINTIFF Deputy
SUIT NO. 21-TX-0357
TEXAS CITY INDEPENDENT SCHOOL DIRECTED TO:
DISTRICT
vs. Evangelina Hernandez Guzman
1416 Y upon St.
EVANGELINA HERNANDEZ GUZMAN La Marque, TX 77568-4240
I received this citation on aaa a8 at, o'clock on M. and:
( ) executed it by delivering a copy of the citation with the date of delivery endorsed on it to defendant,
aan. anne aan. aan
In person on the lay of
20 at “o'clock M. at
aan. aa anna. aan. Haan or
( ) executed it by mailing acopy of the citation via registered/certified mail on the aan
n nn day of
aan. 20 naan ae to defendant _ Haan. aan a.
aan. Aaa anne. Hanne
and attaching the return receipt, with the addressee's signature, to the return; or
( ) did not execute it because a . aan
n ne aan a.
eae aan
n ne Hanne
Total fees: a aaa
of eee County, Texas
By: a -- 88
Deputy
a
COMPLETE IF YOU ARE A PERSON OTHER THAN A SHERIFF, CONSTABLE OR CLERK OF THE COURT.
In accordance with Rule 107: The officer or authorized person who serves, or attempts to serve, a citation shall sign the
return. The signature is not required to be verified. If the return is signed by a personal other than a sheriff, constable, or
the clerk of the court, the return shall be signed under penalty of perjury and contain the following statement:
“My name is , my date of birth is , and my address
(First, Middle & Last)
1s aan. eon
Street, City, State, Zip & Country)
I DECLARE UNDER PENALTY OF PERJURY THAT THE FORGOING IS TRUE AND CORRECT.
Executed in _ ann —a- an County, State of aan , on the aan day of
eae. , 20 —-
pon
Declarant / Authorized Process Server
ans Haan —-
ID Xxpirati
Preview
Filed: 8/2/2022 1:01 PM 1 citation to be issued. Assigned to MM J OHN D. KINARD - District Clerk Galveston County, Texas LINEBARGER GOGGAN BLAIR & SAMPSON, LLP. Envelope No. 66886282 ATTORNEYS AT LAW By: Monique McNeal 8/2/2022 2:02 PM 518 - 9th Avenue North (77590) P. O. Box 2789 Texas City, TX 77592-2789 ——-- + (409) 948-3401 (409) 945-9814 - FAX August 02, 2022 J ohn D. Kinard District Clerk, Galveston County 600 59th St Ste 4001 Galveston, TX 77551-2388 Please note: This citation will be served by a private process server. Please do not assess the service fee for this citation. RE: SUIT NO. 21-TX-0357, GALVESTON COUNTY, ET AL VS. EVANGELINA HERNANDEZ GUZMAN, IN THE 56™ J UDICIAL DISTRICT COURT OF GALVESTON COUNTY, TEXAS Dear Mr. Kinard: Enclosed please find the following document(s): ¥__ Citation(s)to be Re-Issued. Please re-issue the enclosed citation(s). Upon issuance, please forward the issued citation(s) to our office via email in the customary manner. Thank you for your assistance and if anyone concerned has any questions, please feel free to contact our office. Sincerely, Apo CW i Mark E. Ciavaglia Attorney at Law MEC\nlv Enclosure THE STATE OF TEXAS SUIT NO. 21-TX-0357 FOR QUESTIONS CONCERNING THIS LAWSUIT, PLEASE CONTACT THE LAW FIRM OF LINEBARGER GOGGAN STATE OF TEXAS BLAIR & SAMPSON, LLP AS SHOWN BELOW. TO REQUEST COUNTY OF GALVESTON A PAYOFF OF THIS LAWSUIT, PLEASE FAX A WRITTEN REQUEST TO (409) 945-9814OR EMAIL A REQUEST TO: PAY OFF.GALVESTONCOUNTY @LGBS.COM. PLEASE REFERENCE THE SUIT NUMBER IN YOUR REQUEST. TO: Evangelina Hernandez Guzman 1416 Y upon St. La Marque, TX 77568-4240 GREETING: YOU HAVE BEEN SUED. You may employ an attorney. If you or your attomey do not file a written answer with the clerk who issued this citation by 10:00 a.m. on the Monday next after the expiration of 20 days after you were served this citation, a default judgment may be taken against you. In addition to filing a written answer with the clerk, you may be required to make initial disclosures to other parties of this suit. These disclosures generally must be made no later than 30 days after you file your answer with the clerk. Find out more at TexasLawHelp.org. YOU ARE HEREBY COMMANDED to appear and answer, by filing a written answer, before the Honorable District Court, 56th Judicial District, Galveston County, Texas, at 600 59th St Ste 4001, Galveston, TX 77551-2388 at or before 10 o’clock a.m. of the Monday next after the expiration of 20 days from the date of service of this Citation, then and there to answer the Original Petition of the TEXAS CITY INDEPENDENT SCHOOL DISTRICT, Plaintiffs, filed in the said Court on the 23rd day of June, 2021, against Evangelina Hernandez Guzman, Defendant(s). The nature of the suit is a demand to collect delinquent ad valorem taxes, penalties, interest, attorney's fees, court costs and $500.00 in abstractor's fees incurred on the following property: PROPERTY DESCRIPTION Tract 1: Acct. No. 397700000005001 (197220); All that certain tract or parcel of land situated in Galveston County, Texas in the John D. Moore League, in the Townsite formerly known as HIGHLAND CITY, now known as La Marque, being part of the Northeast quarter of Block No. Five (5) and being more particularly described by metes & bounds at File No. 2019038538 in the Office of the Clerk of Galveston County, Texas. Tract 2: Acct. No. 397700000005017 (197245); All that certain tract or parcel of land situated in Galveston County, Texas in the John D. Moore League, in the Townsite formerly known as HIGHLAND CITY, now known as La Marque, being part of the North one-fourth (1/4) of Lot No. Five (5) and being more particularly described by metes & bounds at File No. 2017042460 in the Office of the Clerk of Galveston County, Texas. The Amount of taxes due Plaintiff(s), inclusive of interest and penalties if paid in: JURISDICTION August 2022 September 2022 Texas City Independent School District $2,451.96 $2,468.44 The names of all taxing units which assess and collect taxes on said property, not made parties to the suit, are: GALVESTON COUNTY; CITY OF LA MARQUE; GALVESTON COUNTY DRAINAGE DISTRICT # 02 and COLLEGE OF THE MAINLAND. The foregoing taxing units, if any be shown, are made and joined as parties to this suit and invited to add their claim by intervening herein. There are no taxing units which assess and collect taxes on said property that Plaintiff(s) has failed to join as a party to this suit. Plaintiff(s), and all other taxing units who may set up their tax claims herein seek recovery of delinquent ad valorem taxes on the property and in addition to the taxes, all interest, penalties, attorney's fees, abstractor's fees and court costs allowed by law up to and including the day of judgment, post judgment interest at the maximum rate allowed by law and the establishment and foreclosure of liens securing the payment of same, as provided by law. All parties to this suit shall take notice that claims not only for any taxes which were delinquent on the property at the time this suit was filed but all taxes becoming delinquent at any time thereafter up to the day of judgment, including all interest, penalties, attorney's fees, and costs allowed by law may be recovered without further citation or notice to any parties and all parties shall take notice of and plead and answer to all claims and pleadings now on file and which may be filed in this cause by all other parties and by all of those taxing units above named, who may intervene and set up their tax claims against the property. THE OFFICER OR OTHER AUTHORIZED PERSON EXECUTING THIS RETURN SHALL PROMPTLY SERVE THE SAME ACCORDING TO THE REQUIREMENTS OF LAW AND THE MANDATES HEREOF AND MAKE DUE RETURN AS THE LAW DIRECTS. ISSUED BUT NOT PREPARED BY DISTRICT CLERK’S OFFICE AND GIVEN UNDER MY HANDAND SEAL OF THE COURT AT GALVESTON, TEXAS, this the —--- day of -- ea , 20 —— LINEBARGER GOGGAN JOHN D. KINARD BLAIR & SAMPSON, LLP CLERK OF THE DISTRICT COURTS 518 - 9th Avenue North (77590) OF GALVESTON COUNTY, TEXAS PO Box 2789 600 59TH ST STE 4001 Texas City, TX 77592-2789 GALVESTON, TX 77551-2388 (409) 948-3401 (409) 945-9814 - FAX By: ---- ATTORNEY FOR PLAINTIFF Deputy SUIT NO. 21-TX-0357 TEXAS CITY INDEPENDENT SCHOOL DIRECTED TO: DISTRICT vs. Evangelina Hernandez Guzman 1416 Y upon St. EVANGELINA HERNANDEZ GUZMAN La Marque, TX 77568-4240 I received this citation on aaa a8 at, o'clock on M. and: ( ) executed it by delivering a copy of the citation with the date of delivery endorsed on it to defendant, aan. anne aan. aan In person on the lay of 20 at “o'clock M. at aan. aa anna. aan. Haan or ( ) executed it by mailing acopy of the citation via registered/certified mail on the aan n nn day of aan. 20 naan ae to defendant _ Haan. aan a. aan. Aaa anne. Hanne and attaching the return receipt, with the addressee's signature, to the return; or ( ) did not execute it because a . aan n ne aan a. eae aan n ne Hanne Total fees: a aaa of eee County, Texas By: a -- 88 Deputy a COMPLETE IF YOU ARE A PERSON OTHER THAN A SHERIFF, CONSTABLE OR CLERK OF THE COURT. In accordance with Rule 107: The officer or authorized person who serves, or attempts to serve, a citation shall sign the return. The signature is not required to be verified. If the return is signed by a personal other than a sheriff, constable, or the clerk of the court, the return shall be signed under penalty of perjury and contain the following statement: “My name is , my date of birth is , and my address (First, Middle & Last) 1s aan. eon Street, City, State, Zip & Country) I DECLARE UNDER PENALTY OF PERJURY THAT THE FORGOING IS TRUE AND CORRECT. Executed in _ ann —a- an County, State of aan , on the aan day of eae. , 20 —- pon Declarant / Authorized Process Server ans Haan —- ID Xxpirati