Preview
I I
x
‘
.lLkg wgmflE—E—EWOEEK‘fiM
CAUSE N0.
__9—[.5 APR 29 2020
Maldonado * °A CLERK
Hilda IN THE JUDICIAQA *4
T
a: BY
VS *
STATE DISTRICT COURT
II:
Energy Vision Team, LLC *
8:
Ramon Francisco Rincon * HIDALGO COUNTY, TEXAS
Defendant’s *
PRO SE in PRO FORMA
(ORIGINAL LAW SUIT PETITION)
T0 THE HONORABLE COURT CAPTIONED HEREINABOVE; Comes Hilda Maldonado
collectively the Plaintiff within this cause, and files suit against the Defendant’s
Energy Vision Team, LLC, and Ramon Francisco Rincon, whereof the Plaintiff
within the ground and bases shows this Honorable Court as follows:
JURISDICTION
The Plaintiff files this cause within the correct venue of this court as follow;
1. The Parties are from the same county.
2. The issue in question occurred within this same county.
3. The questioned property in'litigation, lays within this same county.
4. The default in breach of agreement occurred within this same county.
5. The signed contract in written and oral agreements occurred within this
same county. P.1.
Therefore, this suit pertains to this Court whom has jurisdiction over the movant’s
and the property stated in this cause.
DISCOVERY
The Plaintiff requests discovery served on the Defendant's in a || & III level plan,
not limiting Depositions.
BACK GROUND 0F THE CASE
On or about 12/27/2019, the Plaintiff filed an involuntary lien on the Defendant's
property herein described as (Exhibit “A”) Lot number twenty (fl 20), Las Brisas
De San Juan, an addition to the city of San Juan, Hidalgo County, Texas.
The motive and grounds for the Plaintiff’s filed lien on the Defendant’s property is
due to a loan the Defendant borrowed funds form the Plaintiff, Defendant
promising Plaintiff becoming the lien holder, but violated Plaintiff’s Spanish
language not listing Plaintiff as a lien holder, thereafter defaulted reimbursement
to the Plaintiff in the amount of Twenty-Niné ($29,000.00) Thousand dollars &
no/lOO’s, interest not included yet.
DEFENDANT’S LOAN MOTIVE
The Defendant did not have the complete funding amount needed to purchase
the property within the legal description hereinabove, borrowing from Plaintiff
P.2.
the amount needed completing the purchase of this property stated herein
utilizing the Plaintiff as a witness in lieu as a lienholder, therein the Defendant’s
occurring Defendant’s first offence defrauding Plaintiff as the Lien Holder. (see
Exhibit “B" Quit Claim Deed attached herewith)
DEFEN DANT'S ADDITIONAL DEBTS SUMMING THE AMOUNT OWED To
PLAINTIFF
Moreover, the Defendant incurred additional costs on Plaintiff, causing Plaintiff
debt burden Defendant incurring the amount Plaintiff is seeking (see Exhibit “C”
incu rring an additional $8,000.00 amount Defendant falsifying the selling of the
house described herein above to reimburse Plaintiff.
Moreover, during the Defendant's promise t0 pay Plaintiff, additionally Defendant
pror'nised t0 pay Plaintiff for the use of Plaintiff’s Recreational Vehicle (RV)
including utilities consumed where the RV situated within TIP O'TEXAS RV
RESORT, Defenda nt fleeing the park owing the park space renta! including utilities
in the amount of eight thousand, three hundred, forty-one dollars and 71/100’5
($8,341.71), (see Exhibit
"D” attached herewith) the Plaintiff resolving and settling
her issue with TIP O’TEXAS RV RESORT quit claiming and surrendering her RV to
TIP O’TEXAS RV RESORT, in exchange for a full release ofany liability to TIP
P. 3.
O'TEXAS RV RESORT. (see Exhibit “E”, & ”F”)
The Plaintiff up to date currently requests, demands, and bills the Defendant for
the default reimbursement funds owed to the Plaintiff by the Defendant, whereof
Plaintiff now seeks judicial enforcement redressing a grievance summing the
summing of Forty-Nine ($49,000.00) Thousand dollars and no/lOO's. (see Exhibit
“Fnl
RELIEF
The Plaintiff seeks monetary and the highest interest allowable by law at the
courts discretion in full relief to the Plaintiff from the Defendant’s property the
Plaintiff’s lien is placed.
The Plaintiff seeks the courts permission, the court grant Plaintiff the Defendant’s
property in Judgment for the selling of the property reimbursing Plaintiff the
Defendant’s debt in full.
Moreover, the Plaintiff additionally requests the Defendant’s pay the diligence of
Plaintiff, court costs, serving, and mail costs, claiming the Defendant’s debt in the
amount of Ten ($10,000.00) Thousand dollars and n0/100’s.
WHEREFORE PERMISES CONSIDERED, the Plaintiff files this suit against the
Defendants’ Ramon Francisco Rincon, and Energy Team LLC together, due to
P.4.
Defendant Ramon Francisco Rincon deviously, and mala-fide hides this purchased
property home avoiding Plaintiff’s reimbursement. Plaintiff, files suit on the
Defendant’s with evidence seeking relief of the request stated hereinabove
redressing a grievance.
PRAYER
The Plaintiff humbly in prayer, requests this Honorable Court permit, grant, and
let the Plaintiff file this suit against the Defendant’s redressing a grievance, and
seeking reimbursement collecting on the Defendant’s owed debt.
/
rHilda MaldoKaaé
515 Daily Ave.
Weslaco, Texas 78596
(956) 472-1048
CERTIFICATE OF SERVICE
l, The Plaintiff certify, that on thisfijf day of fl/ri Z ,
2020, the
Defendant’s stated hereunder have been served a true and correct copy of this
original suit petition, and in compliance with Texas Rules of Civil Procedure 21(a),
the Defendant’s may be served with substitute service, Via Certified Mail Return
Mail, with Process Server, and/or Constable Sheriff.
P.5.
Ramon Francisco Rincon --------------—---—— Certified Mail Return Receipt
104 Ana Dr. #
San Juan, Texas 78586
(956)
a/xé/
Hilda Maldonad’o
515 Daily Ave.
Wes'laco, Texas 78575
(956) 472-1043 '7 34%
P.6.
Preview
I I x ‘ .lLkg wgmflE—E—EWOEEK‘fiM CAUSE N0. __9—[.5 APR 29 2020 Maldonado * °A CLERK Hilda IN THE JUDICIAQA *4 T a: BY VS * STATE DISTRICT COURT II: Energy Vision Team, LLC * 8: Ramon Francisco Rincon * HIDALGO COUNTY, TEXAS Defendant’s * PRO SE in PRO FORMA (ORIGINAL LAW SUIT PETITION) T0 THE HONORABLE COURT CAPTIONED HEREINABOVE; Comes Hilda Maldonado collectively the Plaintiff within this cause, and files suit against the Defendant’s Energy Vision Team, LLC, and Ramon Francisco Rincon, whereof the Plaintiff within the ground and bases shows this Honorable Court as follows: JURISDICTION The Plaintiff files this cause within the correct venue of this court as follow; 1. The Parties are from the same county. 2. The issue in question occurred within this same county. 3. The questioned property in'litigation, lays within this same county. 4. The default in breach of agreement occurred within this same county. 5. The signed contract in written and oral agreements occurred within this same county. P.1. Therefore, this suit pertains to this Court whom has jurisdiction over the movant’s and the property stated in this cause. DISCOVERY The Plaintiff requests discovery served on the Defendant's in a || & III level plan, not limiting Depositions. BACK GROUND 0F THE CASE On or about 12/27/2019, the Plaintiff filed an involuntary lien on the Defendant's property herein described as (Exhibit “A”) Lot number twenty (fl 20), Las Brisas De San Juan, an addition to the city of San Juan, Hidalgo County, Texas. The motive and grounds for the Plaintiff’s filed lien on the Defendant’s property is due to a loan the Defendant borrowed funds form the Plaintiff, Defendant promising Plaintiff becoming the lien holder, but violated Plaintiff’s Spanish language not listing Plaintiff as a lien holder, thereafter defaulted reimbursement to the Plaintiff in the amount of Twenty-Niné ($29,000.00) Thousand dollars & no/lOO’s, interest not included yet. DEFENDANT’S LOAN MOTIVE The Defendant did not have the complete funding amount needed to purchase the property within the legal description hereinabove, borrowing from Plaintiff P.2. the amount needed completing the purchase of this property stated herein utilizing the Plaintiff as a witness in lieu as a lienholder, therein the Defendant’s occurring Defendant’s first offence defrauding Plaintiff as the Lien Holder. (see Exhibit “B" Quit Claim Deed attached herewith) DEFEN DANT'S ADDITIONAL DEBTS SUMMING THE AMOUNT OWED To PLAINTIFF Moreover, the Defendant incurred additional costs on Plaintiff, causing Plaintiff debt burden Defendant incurring the amount Plaintiff is seeking (see Exhibit “C” incu rring an additional $8,000.00 amount Defendant falsifying the selling of the house described herein above to reimburse Plaintiff. Moreover, during the Defendant's promise t0 pay Plaintiff, additionally Defendant pror'nised t0 pay Plaintiff for the use of Plaintiff’s Recreational Vehicle (RV) including utilities consumed where the RV situated within TIP O'TEXAS RV RESORT, Defenda nt fleeing the park owing the park space renta! including utilities in the amount of eight thousand, three hundred, forty-one dollars and 71/100’5 ($8,341.71), (see Exhibit "D” attached herewith) the Plaintiff resolving and settling her issue with TIP O’TEXAS RV RESORT quit claiming and surrendering her RV to TIP O’TEXAS RV RESORT, in exchange for a full release ofany liability to TIP P. 3. O'TEXAS RV RESORT. (see Exhibit “E”, & ”F”) The Plaintiff up to date currently requests, demands, and bills the Defendant for the default reimbursement funds owed to the Plaintiff by the Defendant, whereof Plaintiff now seeks judicial enforcement redressing a grievance summing the summing of Forty-Nine ($49,000.00) Thousand dollars and no/lOO's. (see Exhibit “Fnl RELIEF The Plaintiff seeks monetary and the highest interest allowable by law at the courts discretion in full relief to the Plaintiff from the Defendant’s property the Plaintiff’s lien is placed. The Plaintiff seeks the courts permission, the court grant Plaintiff the Defendant’s property in Judgment for the selling of the property reimbursing Plaintiff the Defendant’s debt in full. Moreover, the Plaintiff additionally requests the Defendant’s pay the diligence of Plaintiff, court costs, serving, and mail costs, claiming the Defendant’s debt in the amount of Ten ($10,000.00) Thousand dollars and n0/100’s. WHEREFORE PERMISES CONSIDERED, the Plaintiff files this suit against the Defendants’ Ramon Francisco Rincon, and Energy Team LLC together, due to P.4. Defendant Ramon Francisco Rincon deviously, and mala-fide hides this purchased property home avoiding Plaintiff’s reimbursement. Plaintiff, files suit on the Defendant’s with evidence seeking relief of the request stated hereinabove redressing a grievance. PRAYER The Plaintiff humbly in prayer, requests this Honorable Court permit, grant, and let the Plaintiff file this suit against the Defendant’s redressing a grievance, and seeking reimbursement collecting on the Defendant’s owed debt. / rHilda MaldoKaaé 515 Daily Ave. Weslaco, Texas 78596 (956) 472-1048 CERTIFICATE OF SERVICE l, The Plaintiff certify, that on thisfijf day of fl/ri Z , 2020, the Defendant’s stated hereunder have been served a true and correct copy of this original suit petition, and in compliance with Texas Rules of Civil Procedure 21(a), the Defendant’s may be served with substitute service, Via Certified Mail Return Mail, with Process Server, and/or Constable Sheriff. P.5. Ramon Francisco Rincon --------------—---—— Certified Mail Return Receipt 104 Ana Dr. # San Juan, Texas 78586 (956) a/xé/ Hilda Maldonad’o 515 Daily Ave. Wes'laco, Texas 78575 (956) 472-1043 '7 34% P.6.