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Filed: 5/4/2021 9:43 AM
- District Clerk
RECE n County, Texas
Envelope No. 53076656
By: Monique McNeal
THE STATE OF TEXAS APR 15 2021 5/4/2021 10:28 AM
SUIT NO. 21-TX-0164
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) 945-9814 OR EMAIL A REQUEST
TO: PAYOFF.GALVESTONCOUNTY @LGBS.COM. PLEASE
REFERENCE THE SUIT NUMBER IN YOUR REQUEST.
TO: Jerri Battistoni
136 River Birch Cirl&
Lumberton, Hardin County, TX 77657-8693
GREETING: YOU HAVE BEEN SUED. You may employ an attorney. if you or your attorney 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, 122nd Judicial District,
Galveston County, Texas, at 600 59th St Ste 4001,
Galveston, TX 77551-2388 at or before 10 0’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 GALVESTON
COUNTY, CITY OF GALVESTON, GALVESTON INDEPENDENT SCHOOL DISTRICT,
GALVESTON COUNTY NAVIGATION DISTRICT # 01 and GALVESTON COLLEGE, Plaintiffs, filed
in the said Court on the 18th day of March, 2021, against Jerri Battistoni, Jennifer Battistoni Brennan and
Brian Thomas Battistoni, Defendant(s).
The nature of the suit is a demand to collect delinquent ad valorem taxes, penalties, interest, attorney's
fees, court costs and TO BE DETERMINED in abstractor's fees incurred on the following property:
PROPERTY DESCRIPTION
Acct. No. 390000000011000 (119378); Lot Eleven (11) of HEARDS LANE SUBDIVISION REPLAT, a
subdivision of the South 308.00 feet of the North 2 1/2 acres of Lot 79 in Section | of the Trimble & Lindsey
Survey of Galveston Island, in Galveston County, Texas, according to the map or plat thereof recorded in
Volume 15, Page 118 in the Official Map Records in the Office of the County Clerk of Galveston County,
Texas.
The Amount of taxes due Plaintiff(s), inclusive of interest and penalties if paid in:
JURISDICTION March 2021 April 2021
Galveston County $6,954.70 $7,042.12
The names of all taxing units which assess and collect taxes on said property, not made parties to the
suit, are: None. 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
HAND AND SEAL OF THE COURT AT GALVESTON, TEXAS, this the isth day of
March > 2021
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 fb
600 59TH ST STE 4001 \*
Texas City, TX 77592-2789 GALVESTON, TX 77551-2388 Ho.
KS a
(409) 948-3401
(409) 945-9814 - FAX UMNariqus neneat Sar
By:
ATTORNEY FOR PLAINTIFF Deputy
SUIT NO. 21-TX-0164
GALVESTON COUNTY, ET AL DIRECTED TO:
vs. Jerri Battistoni
136 River Birch Circle
JERRI BATTISTONI, ET AL Lumberton, 77651-8693
I received this citation on Adal \Q Wo2l at : 00 o'clock,
ecuted it by delivering a copy of the citation with the date of delivery endorsed on it to defendant,
wm AtisreM
, in. person on the ar day of
AL 20 ZA at G:Z o'clock p M.at {36 y2rvechs tl.
te. LuMmisA® —Ro Mus") 5 or
( ) executed it by mailing
a copy of the citation via registered/certified mail on the day of
» 20. to defendant
and attaching the return receipt, with the addressee's signature, to the return; or
(_) did not execute it because.
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