Preview
Electronically Filed
5/17/2018 9:11 AM
Hidalgo County District Clerks
Reviewed By: Veronica Vazaldua
SUIT NO. T-1643-16-B
HIDALGO COUNTY, CITY OF PHARR, § IN THE DISTRICT COURT
PHARR - SAN JUAN - ALAMO
INDEPENDENT SCHOOL DISTRICT,
SOUTH TEXAS INDEPENDENT SCHOOL
DISTRICT, HIDALGO COUNTY
DRAINAGE DISTRICT # 01 AND SOUTH
TEXAS COLLEGE, ET AL
§
VS. § 93RD JUDICIAL DISTRICT
§
TATIANA MARIE GUERRERO § HIDALGO COUNTY, TEXAS
AFFIDAVIT OF FEES
BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared Michael
G. Cano and upon being duly sworn by me, deposes and says:
I.
My name is Michael G. Cano, I am an attorney licensed to practice law in the State of Texas. I
am over 21 years of age, of sound mind, and capable of making this affidavit. I have personal
knowledge of the facts set forth herein.
II.
I am an attorney in the law firm of LINEBARGER GOGGAN BLAIR & SAMPSON, LLP,
which firm is currently under contract to HIDALGO COUNTY, CITY OF PHARR, SOUTH TEXAS
INDEPENDENT SCHOOL DISTRICT, PHARR - SAN JUAN - ALAMO INDEPENDENT SCHOOL
DISTRICT, SOUTH TEXAS COLLEGE and HIDALGO COUNTY DRAINAGE DISTRICT # 01 for
the collection of delinquent taxes. This contract provides for compensation to the law firm of 15% of
delinquent taxes, penalty and interest collected as set forth below for the year(s): 2017.
JURISDICTION ATTORNEY'S FEE
HIDALGO COUNTY $130.60
CITY OF PHARR $146.14
SOUTH TEXAS INDEPENDENT SCHOOL DISTRICT $11.08
PHARR - SAN JUAN - ALAMO INDEPENDENT SCHOOL DISTRICT $312.82
SOUTH TEXAS COLLEGE $41.66
HIDALGO COUNTY DRAINAGE DISTRICT # 01 $21.41
The total amount of attorney fees due in this case is $663.71
III.
The contract(s) between HIDALGO COUNTY, CITY OF PHARR, SOUTH TEXAS
INDEPENDENT SCHOOL DISTRICT, PHARR - SAN JUAN - ALAMO INDEPENDENT SCHOOL
DISTRICT, SOUTH TEXAS COLLEGE and HIDALGO COUNTY DRAINAGE DISTRICT # 01
and LINEBARGER GOGGAN BLAIR & SAMPSON, LLP are specifically authorized by Section
Suit No T-1643-16-B Page 1 Suit Key No. 2355347
PLAINTIFF EXHIBIT #2
Electronically Filed
5/17/2018 9:11 AM
Hidalgo County District Clerks
Reviewed By: Veronica Vazaldua
6.30 of the Texas Property Tax Code, which statute provides for a maximum of 20% of all delinquent
taxes, penalty and interest collected to be expended by a taxing unit for attorney fees.
IV.
I am familiar with the customary fees charged for the same or similar services performed in the
Hidalgo County area. Based upon my knowledge of such fees, the fees set forth above, on the
delinquent taxes, penalty and interest due each of the aforementioned taxing units are reasonable and
necessary fees for such services.
V.
In the prosecution of this lawsuit, the Plaintiff taxing unit has incurred certain expenses, herein
after referred to as Abstractor's Fees, in determining the name, identity, and location of necessary
parties and in procuring necessary legal descriptions of the property on which delinquent taxes are due.
Pursuant to Article 33.48 of the Property tax code, HIDALGO COUNTY, CITY OF PHARR, SOUTH
TEXAS INDEPENDENT SCHOOL DISTRICT, PHARR - SAN JUAN - ALAMO INDEPENDENT
SCHOOL DISTRICT, SOUTH TEXAS COLLEGE and HIDALGO COUNTY DRAINAGE
DISTRICT # 01 is entitled to recover said Abstractor's Fees, which in this case is $175.00. This fee is
a reasonable and necessary fee for such service.
Respectfully submitted,
LINEBARGER GOGGAN
BLAIR & SAMPSON, LLP
1512 S. Lone Star Way
Edinburg, TX 78539
(956) 383-4500
(956) 383-7820 – FAX
________________________________________
Michael G. Cano
State Bar No. 24047724
Edinburg.Litigation@lgbs.com
Attorney for Plaintiffs
16TH
Sworn to and subscribed before me, the undersigned authority, on this the _______ day of
MAY, 2018.
________________________________________
Roxanne Molina
Notary Public, State of Texas
Suit No T-1643-16-B Page 2 Suit Key No. 2355347
Preview
Electronically Filed 5/17/2018 9:11 AM Hidalgo County District Clerks Reviewed By: Veronica Vazaldua SUIT NO. T-1643-16-B HIDALGO COUNTY, CITY OF PHARR, § IN THE DISTRICT COURT PHARR - SAN JUAN - ALAMO INDEPENDENT SCHOOL DISTRICT, SOUTH TEXAS INDEPENDENT SCHOOL DISTRICT, HIDALGO COUNTY DRAINAGE DISTRICT # 01 AND SOUTH TEXAS COLLEGE, ET AL § VS. § 93RD JUDICIAL DISTRICT § TATIANA MARIE GUERRERO § HIDALGO COUNTY, TEXAS AFFIDAVIT OF FEES BEFORE ME, THE UNDERSIGNED AUTHORITY, on this day personally appeared Michael G. Cano and upon being duly sworn by me, deposes and says: I. My name is Michael G. Cano, I am an attorney licensed to practice law in the State of Texas. I am over 21 years of age, of sound mind, and capable of making this affidavit. I have personal knowledge of the facts set forth herein. II. I am an attorney in the law firm of LINEBARGER GOGGAN BLAIR & SAMPSON, LLP, which firm is currently under contract to HIDALGO COUNTY, CITY OF PHARR, SOUTH TEXAS INDEPENDENT SCHOOL DISTRICT, PHARR - SAN JUAN - ALAMO INDEPENDENT SCHOOL DISTRICT, SOUTH TEXAS COLLEGE and HIDALGO COUNTY DRAINAGE DISTRICT # 01 for the collection of delinquent taxes. This contract provides for compensation to the law firm of 15% of delinquent taxes, penalty and interest collected as set forth below for the year(s): 2017. JURISDICTION ATTORNEY'S FEE HIDALGO COUNTY $130.60 CITY OF PHARR $146.14 SOUTH TEXAS INDEPENDENT SCHOOL DISTRICT $11.08 PHARR - SAN JUAN - ALAMO INDEPENDENT SCHOOL DISTRICT $312.82 SOUTH TEXAS COLLEGE $41.66 HIDALGO COUNTY DRAINAGE DISTRICT # 01 $21.41 The total amount of attorney fees due in this case is $663.71 III. The contract(s) between HIDALGO COUNTY, CITY OF PHARR, SOUTH TEXAS INDEPENDENT SCHOOL DISTRICT, PHARR - SAN JUAN - ALAMO INDEPENDENT SCHOOL DISTRICT, SOUTH TEXAS COLLEGE and HIDALGO COUNTY DRAINAGE DISTRICT # 01 and LINEBARGER GOGGAN BLAIR & SAMPSON, LLP are specifically authorized by Section Suit No T-1643-16-B Page 1 Suit Key No. 2355347 PLAINTIFF EXHIBIT #2 Electronically Filed 5/17/2018 9:11 AM Hidalgo County District Clerks Reviewed By: Veronica Vazaldua 6.30 of the Texas Property Tax Code, which statute provides for a maximum of 20% of all delinquent taxes, penalty and interest collected to be expended by a taxing unit for attorney fees. IV. I am familiar with the customary fees charged for the same or similar services performed in the Hidalgo County area. Based upon my knowledge of such fees, the fees set forth above, on the delinquent taxes, penalty and interest due each of the aforementioned taxing units are reasonable and necessary fees for such services. V. In the prosecution of this lawsuit, the Plaintiff taxing unit has incurred certain expenses, herein after referred to as Abstractor's Fees, in determining the name, identity, and location of necessary parties and in procuring necessary legal descriptions of the property on which delinquent taxes are due. Pursuant to Article 33.48 of the Property tax code, HIDALGO COUNTY, CITY OF PHARR, SOUTH TEXAS INDEPENDENT SCHOOL DISTRICT, PHARR - SAN JUAN - ALAMO INDEPENDENT SCHOOL DISTRICT, SOUTH TEXAS COLLEGE and HIDALGO COUNTY DRAINAGE DISTRICT # 01 is entitled to recover said Abstractor's Fees, which in this case is $175.00. This fee is a reasonable and necessary fee for such service. Respectfully submitted, LINEBARGER GOGGAN BLAIR & SAMPSON, LLP 1512 S. Lone Star Way Edinburg, TX 78539 (956) 383-4500 (956) 383-7820 – FAX ________________________________________ Michael G. Cano State Bar No. 24047724 Edinburg.Litigation@lgbs.com Attorney for Plaintiffs 16TH Sworn to and subscribed before me, the undersigned authority, on this the _______ day of MAY, 2018. ________________________________________ Roxanne Molina Notary Public, State of Texas Suit No T-1643-16-B Page 2 Suit Key No. 2355347