Preview
FILED
6/5/2023 8:09 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Debra Clark DEPUTY
DC-22-16386
Nelda Joyce Johnson Griggs, IN THE DISTRICT COURT
Plaintiff,
Vv. DALLAS COUNTY, TEXAS
Ray Johnson,
Defendants. 134 JUDICIAL DISTRICT
PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE
TO THE HONORABLE JUDGE OF THIS COURT:
NOW COMES PLAINTIFF NELDA JOYCE JOHNSON GRIGGS and files Plaintiff's
First Amended Motion to Reinstate and will show this Court as follows:
I REASON FOR FILING AMENDED MOTION TO REINSTATE: PLAINTIFF
WANTED TO ELIMINATE THE POSSIBILITY THAT THE CLERK
WOULD REJECT THE FILING AS A “MOTION FOR NEW TRIAL”
WITHOUT PAYING THE FILING FEES AND SO THIS DOCUMENT WAS
EDITED TO ELMINATE THAT CATCH PHRASE AND TO STICK TO THIS
BEING A MOTION TO REINSTATE,
The word “New Trial” was inadvertently in the Motion to Reinstate and since this is not a
motion for new trial, there was a concern that this needed to be amended to avoid confusion of
the basis of the motion to reinstate a case where the issues were dismissed without prejudice.
PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE
B. THE LONGER WE REVIEW THE FORGED DEED OF 2004, THE GREATER
NUMBER OF “ON ITS FACE” DEFECTS THAT WE ARE ABLE TO FIND AND
PLAINTIFF DID NOT WANT TO DISTURB THIS POLCY.
There are actually at least 5-6 reasons why the 2004 Deed that Plaintiff says is a forgery
(filed in 2005) appears on its face to be the forgery that Plaintiff complains of:
(1) Mr. Johnson (divorced in 1992) would not have his name on a 2004 filing, since Ms.
Griggs got to keep the Plum Dale Road home in the divorce.
(2) Whomever signed for Mr. Johnson was not Ms. Grigg’s first husband (forgery) and
his alleged signature does not match the signature he gave on the marriage license
application.
(3) Mr. Johnson in 2004 would not have his name beside the name of Mrs. Nelda
Johnston, because Mrs. Nelda Joyce Johnson Griggs took on the Griggs name by late
2004 and she would not have signed as “Mrs. Johnson” next to “Mr. Johnson” in
2004 if she was going by “Mrs. Griggs” after the marriage to Mr. Griggs.
(4) The 2022 document from the Family Law Court that the 134" was interested in also
verifies that Ms. Griggs kept Plum Dale Road on her own.\
(5) If an adult male needed to sign with Ms. Griggs in 2004, then it would be a document
where 2 Griggs were verifying that Ms. Grigg’s owned the Plum Dale Road address
with the tenants in it instead.
(6) Ms. Griggs will be able to demonstrate that her professional signature, when she is
not using a mouse or phone screen to sign or review documents looks different than
the signature on the 2004 document.
PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE
Other facts suggesting that Plaintiff is correct on the merits of the case and hence the
merits of the motion to reinstate are:
(a) Mr. Ray Johnson has some address issues, whereas a lot of the mail
correspondence is rejected/comes back when one compares the records on DCAD
with that Mr. Johnson really owns.
(b) Mr. Johnson appears to be very reluctant to appear and answer questions under
oath and it appears that some practices, such as (according to the lawnmowing
service) hiring a lawnmowing service and not paying them and then claiming an
interest in the liens related to lawn mowing services, even if he is not the proper
party to collect the lawn moving service’s fees.
(c) Mr. Johnson, if the reinstatement is granted, will be asked to provide a copy of the
underlying documents showing how and when he gave money to or negotiated the
purchase of Plaintiff's property at Plum Dale Road and
I. SUMMARY: NEW ATTORNEY FOUND THE DOCUMENTS
MS GRIGGS WAS DISMISSED WITHOUT PREJUDDICE AND NEEDS THE
MOTION FOR REHARING TO BE GRANTED TO AVOID POSSIBLE LMITATIONS
ISSUES. SHE WAS BASICALLY FIGHTING VERY CHRONIC DISEASES FOR 15-20
YEARS AND THAT WAS WHEN A FORGED DEED WAS FILED.
NOW, MS. GRIGGS HIRED COUNSEL WHO CAN HELP THE COURT
UNDERSTAND WITH THE CORRECT DOCUMENTS THAT THE 2005 DEED WAS
FORGED AND THAT THE FORGER EVEN USED THE WRONG NAME IN 2005 (SHE
WAS USING LAST NAME OF GRIGGS AND WOULD NOT HAVE SIGNED AS MRS.
JOHNSON ALONG WITH EX HUSBAND MR. JOHNSON IN LATE 2004 ~ JUST LIKE
PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE
JOHNSON NAME). AND APART FROM DIFFERNET LOOKING SIGNATURES, MR.
Hil. THIS MOTION IS TIMELY
The Court dismissed this case “without prejudice” on May 4, 2023. Since the 30" day
from May 4, 2023 falls on a weekend, then Monday June 5, 2023 is within the filing deadline for
a motion for reinstatement/motion to reinstate (which has a 30 day from dismissal deadlines,
similar to the deadline for a motion for new trial).
IV. EVIDENCE IN SUPPORT OF THE MOTION TO REINSTATE, OTHER
THAN THE DECLARATION (WHICH ALSO HAS ATTACHMENTS)
A MAY 2004 CHILD SUPPORT ABSTRACT OF JUDGMENT BETWEEN
FIRST HUSBAND BRADY JOHNSON III AND NELDA GRIGGS.
FORGED DEED FROM NOVEMBER 2004 (FILED IN 2005) THAT
PLAINTIFF SEEKS TO AMEND WITH 2 SIGNATURES EVEN THOUGH
ONLY OWN PERSON GRIGGS OWNED HER DEED POST 1992 DIVORCE
NAMES: BRADY JOHNSON III AND “NELDA JOHNSON” AS SIGNORS
Copy of 2022 Dallas Family Law Court order confirming that Griggs
Ms. is the
sole owner of the land in question (and that Mr. Johnson’s signature would not be
tequired, i.e. evidence of forgery).
Copy of Child Support Judgment close in time (from 2006) showing the correct
names would be “Nelda Griggs” opposite Mr. Johnson’s name if he was a 50%
owner.
PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE
Signature page of different deed from Mr. Brady Johnson III, to compare with
Exhibit B (not the same person).
1982 Deed demonstrating Plaintiff acquired Plum Dale originally with Mr.
Johnson during Marriage.
G Charles Wood fraudulent deed on other Plum Dale property next door — Plaintiff
did not sign this and Neither did Mr. Johnson — Plaintiff suspects Mr. Ray
Johnson learned something from Mr. Wood.
H. Johnson DCAD — too many properties for City code enforcer’s salary.
GRANTING A MOTION TO REINSTATE MAY KEEP OTHERS FROM
BEING DEFRAUDED, PLAINTIFF NEEDS THIS COURT TO GRANT THE
MOTION TO REINSTATE REGARDING THE 5846 PLUM DALE ROAD
PROPERTY.
The Court and parties have a special interest in preventing fraud. A purchaser who did not
know any better could easaily pay a nice price for the real property at 50% DCAD value, etc. and
have no idea of the claim of forgery if this Court does not allow the reinstatement to occur (and
effectively this would not allow a lis pendens to be filed).
Plaintiff has attached documents with the legal description and Plaintiff has declared
that she did not sell or convey 5846 Plum Dale Road in Dallas, Texas to Defendant Ray
Johnson. It is suspected that Ray Johnson, a stranger is the person at the City of Dallas
who filed Code Enforcement cases against Ms. Griggs and other property owners in that
area (and later tried to trick other neighbors out of their property);
PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE
LOT 5 OF CARVER HEIGHTS ADDITION, AN ADDITON TO THE CITY OF
DALLAS SITUATED IN CITY BLOCK 7/6889 IN THE CITY OF DALL, DALLAS
COUNTY, TEXAS AS SHOWN BY DEED RECORDED IN VOLUME 2005024 PAGE
3563 OF THE DEED RECORDS OF DALLAS COUNTY, TEXAS AND MORE
COMMONLY ADDRESSED AS 5846 PLUM DALE ROAD, DALLAS, DALLAS
COUNTY, TEXAS
VI. THE DECLARATION OF NELDA JOYCE JOHNSON GRIGGS SUPPORTS
THE REINSTATEMENT (ATTACHED SEPARATELY).
The declaration states it more generally, but Plaintiff was basically scared to death for her
life (although she reacted with a lot of courage) because of almost non stop serious health
threats that she did expect on the front end — this most likely results in an “incapacity”
tolling of issues as well as the “discovery rule” that Defendant did not notify Plaintiff of
his fraudulent deed and Plaintiff certainly did not receive a big check from Defendant.
Specifics regarding various medical scares - She was dying and fighting cancer and other
aggressive diseases when the forged deed was apparently filed. Since she was expecting
to die within a year, etc. In 2000-2002 Plaintiff was on the “heart transplant list” because
of a defect in her heart resulted in damages to the tissue of the heart and that caused her
to collapse (upon Baylor’s recommendation). Plaintiff then had to go on a “trial
medication” that appeared to help and the initial trials worked out pretty well — i.e. the
PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE
drug was approved. Plaintiff dealt with breast cancer for about 5 years starting closer to
2009. Plaintiff had two strokes AFTER
Forged deeds are void/nullities. Plaintiff affirms that she did not sign the deed that
allegedly would give a property interest to Ray Johnson.
Cc The forgers messed up and used the wrong married name, meaning that just like the
attached Child Support documents from 2004 to 2006, Ms. Griggs went by Mrs. Griggs
when married to second husband, Mr. Griggs and would not have signed with Mr.
Johnson as “Mrs. Johnson” in 2004 when she was married to Griggs.
A comparison of Ms. Grigg’s signatures to the incorrect, “Ms. Johnson” also suggest that
a different person, with a different signature is signing and Ms. Griggs testified that she is
the owner of the property and provided a copy of the 1992 divorce from Johnson
(affirmed again in 2022) that Ms. Griggs is the owner of the real property after/since the
divorce (that it did not transfer to her husband in 1992 and so he would not have signed
off
of on the Plum Dale Property in 2004, since he would be 0% owner, not 50% Griggs
50% ex husband Brady Johnson, III.).
VM THISINTEREST OF JUSTICE, ANDINNOF MADETODELAN.
PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE
This motion is not filed to delay or waste time. No party is prejudiced by its filing.
There is a real risk that if this case is not reinstated that other people could be victims, too,
because without a record and/or Lis Pendens filed, other purchasers or renters may be deceived by
the forged 2005 deed and pay money for bad title.
Forged deeds have no title-passing powers (are a nullity/void), so there is a great interest
in promoting justice by preventing fraud. Additionally, as a person who was very ill, Plaintiff has
a legitimate interest in a determination as to whether a city official tried to take advantage of her
or her family name.
VIII. PRAYER
Plaintiff prays that this Court will set the Motion to Reinstate for a Hearing, reinstate the
case and have a real final trial on the pled cause of actions as well as allow Plaintiffto amend the
pleadings to allege a cloud on title, declaratory judgment, fraud, etc., with the discovery rule and
incapacitation pled, since Plaintiff was told that she would died very soon from one of several
diseases and spent 15 -20 years taking very extreme treatments to cancers, etc.
Plaintiff promises that Plaintiff's counsel will make this case very easy to understand.
Respectfully submitted,
Ciarochi Law Firm,PLLC
/s/ Jason Charles Ciarochi
Jason Charles Ciarochi
State Bar No. 24012424
P. O. Box 29256
Dallas, Texas 75229
(214) 642-2424
(214) 242-2791 (£)(call first)
PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE
Jason@ciarochilaw.com
ATTORNEY FOR NELDA
JOYCE JOHNSON
GRIGGS
CERTIFICATE OF SERVICE AND CONFERENCE
Pursuant to the TRCP, true and correct copies are served via on 6.5.23. THERE WAS
NOT ENOUGH TIME, COMING INTO THIS CASE AFTER FINISHING A WEEK LONG
ARBITTATION WITH 10 ATTRONEYS TO CONFER, BUT I WILL CONFER BEFORE
SETTING FOR A HEARING.
/s/ Jason Charles Ciarochi
Jason Charles Ciarochi
HEARING FIAT
It is hereby ordered that PLAINTIFF’S MOTION TO REINSTATE CASE shall be heard
in the Courtroom of the 134" State District Court, Honorable Dale Tillery Presiding, off of
Commerce Street, Dallas Texas 75201 in Dallas County Texas, on the _ _ day of [circle
one] JUNE / JULY, 2023. Signed on this day of June, 2023.
JUDGE PRESIDING
NOTE THIS HEARING NEEDS TO OCCUR BEFORE JULY 15, 2023
PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE
IMAGE SUMMARY < Prev Doc Next Doc >
®
| 1 of 2 @ Add To Cart
AGL ancue98826
2s
Notice of Child Support Lie
(Name/Addess oF recorderor
set holder)
ou BRADY JOHNSON 1
§)
(Mame. AdtesvDOB, SSN) (MC2 KINNEY
CYPRESS HL
PX 75071-3708
Dow 421
SSN
FR OFFICE OF THE ATTORNEY GENERAL
VID Agency (Claman (CHILD SUPPORT UN
12221 § WALTON WALKER BLVD,
s 1
DALLAS. 1X 18236
“TelepieneNo. 214)330-591,
“oll Free |(80)687-529),
Fa No. (21493392368
ot NEL a Gn
(Office ofthe Anomney
[NLDA JOYCE jgnment
GRIGCS)fom
IV. Case Number
“This en ress fom child soppy "751/2006 wy 254TH DISTRICT COURT. DALLAS COUNTY,
‘TEXASin rbona umber 9205987
As of 10212006 the we) Judge inthe amount oF $20,354.03. This agent
may be subject
‘ners.
=oKS y ot pid when du are gre that read othe len amount. This Te.
stiches SOs ee J ea ear personal popsty of the abevesnamed obligor which is oete or exiting
within
the tatocount Fe inelodingry peopeny specifically described below.
Specific description of rope:
Page tof?
Le. >
of 2
AOC oncoe98826
ame
Notice of Child Support Lien
(NameiAdess ofrecorderor
eset holder)
opLicor: BRADY JOHNSON 1
(ame, Addres'DOB, SSN) 2 CYPRESS HL
(MC KINNEYPX 75071-3708
Dow 421
SSN:
&
f QM (OFFICE OF THE ATTORNEY GENERAL
(QV-D Ageney ‘Claimant (CHILD SUPPORT UN
£2221 § WALTON WALKER BLVD,
s 1
DALLAS, 1x 18236
“TelepioneNo. 214)330-591,
“oll ree 1(80)687-829),
Fe No. (214)339.2368
ot A NELDA JOYCE GRI
oft re sti Ass &
[NELDA JOYCEassignment
GRIGCS)fom
IV-D Case Number:
“This ien ress fom child soppy
‘TEXASin rbona umber 9205987
© "51/2006 wy 254TH DISTRICT COURT. DALLAS COUNTY,
5: A of 10272006, the oblige LD) reer ant
‘eters.
De
Prospect ot pid when du, are gre that read othe len amount This Te
stiches J ea enor personal popsty of the abevesamed obligor which is loeted
or exiting within
the tatecount Fe ineloding any peopenty specifically described below.
‘Specific description af rope:
Ri
Paget?
To
th
ee 86>
s -- wees - wee =
of 2
AOC rancue98806
ame
Notice of Child Support Lien
(NameiAdess ofrecorderor
eset holder)
ou © BRADY JOHNSON I
(ame, AddressDOB, SSN) (MCU2 KINNEY
CYPRESS HL
PX 75071-3708
Dow 421
SSN:
&
FROM: OFFICE OF THE ATTORNEY GENERAL
V-D Agoney /Claimant) (CHILD SUPPORT UN
£2221 § WALTON WALKER BLVD,
s 1
DALLAS, 1X 18236
“TelepcneNo. 214)330-4591,
“oll Free |(80)687-829),
Fx No. (214)339.2368
ot A NELDA JOYCE GRI
oft re cations &
[NELDA JOYCE inert
GRIGCS)fom
IV-D Case Number:
“This ies resus fom child soppy
‘TEXASin rpona umber 9205987
© "51/2006 wy 254TH DISTRICT COURT. DALLAS COUNTY,
A of 10272006, the oblige Judgont nthe amount oF $20,354.03. This jagment
may be subject
‘meres.
Prospect ot pid when du, are gre that te ad othe len amount. This Te
stiches J ea ear personal popsty of the abevesamed obligor which is loeted
or exiting within
the Statocount Fe inelodingany peopenty specifically described below.
‘Specific desertion f prope:
Paget?
ee 86>
IMAGE SUMMARY < Prev Doc | Next Doc >
| 1 of 2 Add To Cart
WARRANTY DEED
“THE STATEOF TEXAS am
‘COUNTY OF DAL AS.
“Tul BRADY JOMNSON M1 Sts& NELDA.
100 (DOLLARS) exh enof Dal, of Tan
inh vam
RAY JOLINSOR, here calcd GRANT: chin id
eve Ged Sld nd Convey an“eal Selcr nd Cae,te
‘tosUtena!opal hig ra atc ot
WAY ofJOHNSON
sce lowe oe.
LEGAL DESCRIPTION:
io Das, Ten Map(IGHTS
or Pat ADDITION, a Addin tthe
ecard of Balin’ Coun, Teas
TOHAVE AND; opt
nr
ns tery bares fGRANTEEsigur
wih al Notesbe
ng
ed VER siDEFREND.
sgn alanner pero
seg wee
cing
ad JOHNSON oa Mt 2 26
SELLER: BRADY JOHNSON i & NEEDAJO Washo
Celle A
Saniora ms us
“eee aw hee OF
NOTARY Phe TATE
OF ENS Soe
mel
ms02% U3563-
Loess hig een
re 86}
1
De
of 2
Re
To
th
WARRANTY DEED ses
‘THE STATEOF TEXAS wenn
‘COUNTY OF DAL AS
om ‘Raby JonNson
100 (DOLLARS) exh eni So Ten
inhamid
sinTA NGO hoe ced CHARTER
oe Gullo Cr dy Gra
tem
‘ator preRAY JOHNSON
of ad a a sce“eal Slcernd Cae, no
lle oe
{LEGAL DESCRIPTION:
iyo Das, Ten Map(IGHTS ADDITION,
Records a Addin tthe
‘Coun, Teas
TOHAVE AND,
caer naee teeta ate ih anaNees
‘id GRANTEE
ns
{VER DEFREND. lun hry brute ‘ad prema dng
or
aha seat ce porn cnr ning
ad JOHNSON ont: 2 26
SELLER: BRADY JOHNSON I & NELDA JOM
fs — (a chaaon
Ta us
i
EBS
&,
NOTARY Phe TATE
eiaeweente
OF ENS
3 twat fe? Of
oe
Soa
ms024 v3563-
Loess hig vem
ee 86}
1-
De
of 2
Re
To
th
WARRANTY DEED ses
‘THE STATEOF TEXAS wenn
‘COUNTY OF DALLAS.
om ‘Raby Jonsson
100 (DOLLARS) chensi So Ten
inhamid
sinTAY USO hoe ced CHARTER
oe Gel Slo Cra dy ran
tem
‘ator peWAY JOHNSON
fad a sce“femal Selcrnd Cae,
le oe.
{LEGAL DESCRIPTION:
io Das, Ten Map(IGS ADDITION,
Records a Addin tthe
‘Coun, Teas
TOHAVE AND,
caer nee teeta ateid GRANTEE ih anaNees
ns
'VERDEFREND. lun hry brute ‘ad penis dng
or
aha seat ce pn wc nig
ad JOHNSON ont: 2 26
SELLER: BRADY JOHNSON I & NELDA JOM
fs — (ie ehason
TET us
i
EBS ios
&.
NOTARY Phe TATE
eiaeweente
OF ENS
3 twat fe? Af
oe
Soar
ms02% U3563-
Loess hig vem
ee 86>
IMAGE SUMMARY < Prev Doc Next Doc >
®
| 1 of 2 @ Add To Cart
(HUTA rancue98806
ame
Notice of Child Support Lien
(NameiAdess ofrecorderor
set holder)
opLicor: BRADY JOHNSON 1
§)
(ame, Address'DOB, SSN) 2 CYPRESS HL
MC KINNEYPX 75071-3708
“a2
SSX:
FROM: OFFICE OF THE ATTORNEY GENERAL
V-D Ageney /Claimant) (CHILD SUPPORT UN
£2221 § WALTON WALKER BLVD,
s 1
DALLAS, 1X 18236
“TelepeneNo. 214)330-591,
“oll Free 1(80)687-329),
Fe No. (214)330.2368
onLicer: NELDA JOYCE GRI
(Office ofthe Anomey
'NELDA JOYCEassignment
GRIGCS)fom
IV-D Case Number: of
“This ies ress fom child soppy "51/2006 wy 254TH DISTRICT COURT. DALLAS COUNTY,
‘TEXAS rbona umber 9205987
A of 10272006 the oblige LB) rev santa
‘ees.
Prospect ot pid when dare gre that te ad othe len amount. Thi Te.
stiches J ea ear personal popsty of the abevesamed obligor which is loeted
or exiting within
the Statocount Fe ineloding any peopenty specifically described below.
‘Specific description af rope:
Paget?
JOHNSON NELDA
——— ee — (is >
of 2
ACL oncoe98826
ame
Notice of Child Support Lien
(NameiAdess ofrecorderor
set holder)
opLicor: BRADY JOHNSON 1
(ame, Addres'DOB, SSN) 2 CYPRESS HL
(MC KINNEY PX 75071-3708
Dow 421
SSN:
&
f QM OFFICE OF THE ATTORNEY GENERAL
(QV-D Ageney ‘Claimant (CHILD SUPPORT UN
£2221 § WALTON WALKER BLVD,
s 1
DALLAS, 1X 15236
“elepieneNo. 214)330-591,
“oll ree 1(80)687-529),
Fx No. (214)339.2368
ot A NELDA JOYCE GRI
ort re sti Ass &
[NLDA JOYCEassignment
GRIGCS)fom
IV-D Case Number:
“This en resus fom child soppy
‘TEXASin bona umber 9205987
© 51/2006 wy 254TH DISTRICT COURT. DALLAS COUNTY,
5: A of 10272006, the oblige LB) reeves eta
‘eters.
De
Prospect ot pid when du, are gre that re ad othe Len amount This Te
stiches J ea ear personal popsty of the abevesamed obligor which is oeted
or exiting within
the Statocount Fe inelodingny peopenty specifically described below.
‘Specific deveiption of rope:
Ri
Paget?
To
th
JOHNSON NELDA
D> =8=6—>
s -- wees - wee =
of 2
AOC rancue98806
ame
Notice of Child Support Lien
(NameiAdess ofrecorderor
eset holder)
ou © BRADY JOHNSON I
(ame, AddressDOB, SSN) (MCU2 KINNEY
CYPRESS HL
PX 75071-3708
Dow 421
SSN:
&
FROM: OFFICE OF THE ATTORNEY GENERAL
V-D Agoney /Claimant) (CHILD SUPPORT UN
£2221 § WALTON WALKER BLVD,
s 1
DALLAS, 1X 18236
“TelepcneNo. 214)330-4591,
“oll Free |(80)687-829),
Fx No. (214)339.2368
ot A NELDA JOYCE GRI
oft re cations &
[NELDA JOYCE inert
GRIGCS)fom
IV-D Case Number:
“This ies resus fom child soppy
‘TEXASin rpona umber 9205987
© "51/2006 wy 254TH DISTRICT COURT. DALLAS COUNTY,
A of 10272006, the oblige Judgont nthe amount oF $20,354.03. This jagment
may be subject
‘meres.
Prospect ot pid when du, are gre that te ad othe len amount. This Te
stiches J ea ear personal popsty of the abevesamed obligor which is loeted
or exiting within
the Statocount Fe inelodingany peopenty specifically described below.
‘Specific desertion f prope:
Paget?
ee 86>
IMAGE SUMMARY < Prev Doc Next Doc >
®
| 1 of 3
=
@ Add To Cart
once
1118 Page 10
A
"AUSE NO, 92.5957.
GRIGGS NELDA JOYCE
INTHE MATTER: ‘THE MARRIAGE, 5
‘OF JOYCE JOHN: AND BRADY 8 JOHNSON BRADY III
JOHNSON,It, JOHNSON JOYCE
DALLAS COU!
ORDE ° FIN:
The C vena ‘cnn a : oe os
1993 i clarified by adding the folowing section:
> 18,
REAL PROPERTY
TO PETITIONER
Petone, Neda Joyce riggs forme J the real property
losted at
Being Block 16889] Lot 5, CARVER HEIGASTS fn Addition tothe Cty of Dallas,
“Texas acording tothe Map or Pat fants, Texas more commonly knows as
5846 Plum Dale Rd, Dalle, aspect ofthe Order entered by this Cour
‘on Jone 18, 199, remain
TIS ORDERED, Motion wo Clarify Final Decree of Divarce Judgment is
GRANTED;
LS 3 fe OC Selo 2022.
<3 ‘JUDGE PRESIDING
Fhe,
ete
de?
LLL =|
GRIGGS NELDA JOYCE JOHNSON BRADY III CHILD SUPPORT LIEN 10/25/2006
®
of 3
once
1118 Page ot
A
Ri (CAUSE NO. 92.5957.
GRIGGS NELDA JOYCE
INTHE MATTER: ‘THE MARRIAGE, 8
To ‘OF JOYCE JOHN: AND BRADY JOHNSON BRADY III
JOHNSON,It, § JOHNSON JOYCE
th
DALLAS COU
ORDE ° FINA
The C vena ‘cnn a : oe os
1993 i clarified by adding the folowing section:
> 18,
REAL PROPERTY, TO PETITIONER
etitoner,Nida Joyce Griggs (formetiyJo the real propetylostedat
Being Block 16889] Lot 5, CARVER HEIGASTS fn Addition tothe Cty of Dallas,
‘Texas avordng tothe Map or Pat fants, Texas more commonly knows a5
$846 Plum Dale Rd, Dali, Ts aspects ofthe Order entered by this Cour
‘on Jone 18, 199, remain
TIS ORDERED, ‘Motion wo Clay Final Decree of Diver Judgment is
GRANTED;
LS 3 tot OCH? bCC oom
32 ‘JUDGE PRESIDING
Fhe,
ete
a?
iove
LLL =|
NOTICE
Preputed by tho State One of Texus for use by Lawyers only.
To telect the proper form, fill in blenk 4 HH, sirike out. 1 provitions op intent
pela teeras conitibutes the practice of lew. “etene form" can meet all
require
WARRANTY DEED WITH VENDOR'S LIEN
THE STATE OF TEXAS 47s $ 4 10/05/82
KNOW ALL MEN BY THESE PRESENTS:
COUNTY OF DALLAS
That I, ALBERTA THOMAS, a widow
of the County of Dallas and State of Texas for and
in consideration of the sum of TEN AND NO/100 ($10.00) --~---~—----- eeee= DOLLARS
and other valuable consideration
to the undersigned paid by the grantee herein named, the receipt of
which is heroby acknowledged, and the further consideration of the execution and delivery by
Grantees of their one certain promissory note of eben date herewith, in
in the prinicpal sum of TWENTY-EIGHT THOUSAND FIVE HUNDRED ($28,500.00)
DOLLARS, payable to the order of Grantor in monthly installments and
bearing no interest as therein provided, containing the usual clauses
providing for acceleration of maturity and for attorney's fees.
DOA
gi
of DALLgs
+\i
Preview
FILED 6/5/2023 8:09 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Debra Clark DEPUTY DC-22-16386 Nelda Joyce Johnson Griggs, IN THE DISTRICT COURT Plaintiff, Vv. DALLAS COUNTY, TEXAS Ray Johnson, Defendants. 134 JUDICIAL DISTRICT PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE TO THE HONORABLE JUDGE OF THIS COURT: NOW COMES PLAINTIFF NELDA JOYCE JOHNSON GRIGGS and files Plaintiff's First Amended Motion to Reinstate and will show this Court as follows: I REASON FOR FILING AMENDED MOTION TO REINSTATE: PLAINTIFF WANTED TO ELIMINATE THE POSSIBILITY THAT THE CLERK WOULD REJECT THE FILING AS A “MOTION FOR NEW TRIAL” WITHOUT PAYING THE FILING FEES AND SO THIS DOCUMENT WAS EDITED TO ELMINATE THAT CATCH PHRASE AND TO STICK TO THIS BEING A MOTION TO REINSTATE, The word “New Trial” was inadvertently in the Motion to Reinstate and since this is not a motion for new trial, there was a concern that this needed to be amended to avoid confusion of the basis of the motion to reinstate a case where the issues were dismissed without prejudice. PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE B. THE LONGER WE REVIEW THE FORGED DEED OF 2004, THE GREATER NUMBER OF “ON ITS FACE” DEFECTS THAT WE ARE ABLE TO FIND AND PLAINTIFF DID NOT WANT TO DISTURB THIS POLCY. There are actually at least 5-6 reasons why the 2004 Deed that Plaintiff says is a forgery (filed in 2005) appears on its face to be the forgery that Plaintiff complains of: (1) Mr. Johnson (divorced in 1992) would not have his name on a 2004 filing, since Ms. Griggs got to keep the Plum Dale Road home in the divorce. (2) Whomever signed for Mr. Johnson was not Ms. Grigg’s first husband (forgery) and his alleged signature does not match the signature he gave on the marriage license application. (3) Mr. Johnson in 2004 would not have his name beside the name of Mrs. Nelda Johnston, because Mrs. Nelda Joyce Johnson Griggs took on the Griggs name by late 2004 and she would not have signed as “Mrs. Johnson” next to “Mr. Johnson” in 2004 if she was going by “Mrs. Griggs” after the marriage to Mr. Griggs. (4) The 2022 document from the Family Law Court that the 134" was interested in also verifies that Ms. Griggs kept Plum Dale Road on her own.\ (5) If an adult male needed to sign with Ms. Griggs in 2004, then it would be a document where 2 Griggs were verifying that Ms. Grigg’s owned the Plum Dale Road address with the tenants in it instead. (6) Ms. Griggs will be able to demonstrate that her professional signature, when she is not using a mouse or phone screen to sign or review documents looks different than the signature on the 2004 document. PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE Other facts suggesting that Plaintiff is correct on the merits of the case and hence the merits of the motion to reinstate are: (a) Mr. Ray Johnson has some address issues, whereas a lot of the mail correspondence is rejected/comes back when one compares the records on DCAD with that Mr. Johnson really owns. (b) Mr. Johnson appears to be very reluctant to appear and answer questions under oath and it appears that some practices, such as (according to the lawnmowing service) hiring a lawnmowing service and not paying them and then claiming an interest in the liens related to lawn mowing services, even if he is not the proper party to collect the lawn moving service’s fees. (c) Mr. Johnson, if the reinstatement is granted, will be asked to provide a copy of the underlying documents showing how and when he gave money to or negotiated the purchase of Plaintiff's property at Plum Dale Road and I. SUMMARY: NEW ATTORNEY FOUND THE DOCUMENTS MS GRIGGS WAS DISMISSED WITHOUT PREJUDDICE AND NEEDS THE MOTION FOR REHARING TO BE GRANTED TO AVOID POSSIBLE LMITATIONS ISSUES. SHE WAS BASICALLY FIGHTING VERY CHRONIC DISEASES FOR 15-20 YEARS AND THAT WAS WHEN A FORGED DEED WAS FILED. NOW, MS. GRIGGS HIRED COUNSEL WHO CAN HELP THE COURT UNDERSTAND WITH THE CORRECT DOCUMENTS THAT THE 2005 DEED WAS FORGED AND THAT THE FORGER EVEN USED THE WRONG NAME IN 2005 (SHE WAS USING LAST NAME OF GRIGGS AND WOULD NOT HAVE SIGNED AS MRS. JOHNSON ALONG WITH EX HUSBAND MR. JOHNSON IN LATE 2004 ~ JUST LIKE PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE JOHNSON NAME). AND APART FROM DIFFERNET LOOKING SIGNATURES, MR. Hil. THIS MOTION IS TIMELY The Court dismissed this case “without prejudice” on May 4, 2023. Since the 30" day from May 4, 2023 falls on a weekend, then Monday June 5, 2023 is within the filing deadline for a motion for reinstatement/motion to reinstate (which has a 30 day from dismissal deadlines, similar to the deadline for a motion for new trial). IV. EVIDENCE IN SUPPORT OF THE MOTION TO REINSTATE, OTHER THAN THE DECLARATION (WHICH ALSO HAS ATTACHMENTS) A MAY 2004 CHILD SUPPORT ABSTRACT OF JUDGMENT BETWEEN FIRST HUSBAND BRADY JOHNSON III AND NELDA GRIGGS. FORGED DEED FROM NOVEMBER 2004 (FILED IN 2005) THAT PLAINTIFF SEEKS TO AMEND WITH 2 SIGNATURES EVEN THOUGH ONLY OWN PERSON GRIGGS OWNED HER DEED POST 1992 DIVORCE NAMES: BRADY JOHNSON III AND “NELDA JOHNSON” AS SIGNORS Copy of 2022 Dallas Family Law Court order confirming that Griggs Ms. is the sole owner of the land in question (and that Mr. Johnson’s signature would not be tequired, i.e. evidence of forgery). Copy of Child Support Judgment close in time (from 2006) showing the correct names would be “Nelda Griggs” opposite Mr. Johnson’s name if he was a 50% owner. PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE Signature page of different deed from Mr. Brady Johnson III, to compare with Exhibit B (not the same person). 1982 Deed demonstrating Plaintiff acquired Plum Dale originally with Mr. Johnson during Marriage. G Charles Wood fraudulent deed on other Plum Dale property next door — Plaintiff did not sign this and Neither did Mr. Johnson — Plaintiff suspects Mr. Ray Johnson learned something from Mr. Wood. H. Johnson DCAD — too many properties for City code enforcer’s salary. GRANTING A MOTION TO REINSTATE MAY KEEP OTHERS FROM BEING DEFRAUDED, PLAINTIFF NEEDS THIS COURT TO GRANT THE MOTION TO REINSTATE REGARDING THE 5846 PLUM DALE ROAD PROPERTY. The Court and parties have a special interest in preventing fraud. A purchaser who did not know any better could easaily pay a nice price for the real property at 50% DCAD value, etc. and have no idea of the claim of forgery if this Court does not allow the reinstatement to occur (and effectively this would not allow a lis pendens to be filed). Plaintiff has attached documents with the legal description and Plaintiff has declared that she did not sell or convey 5846 Plum Dale Road in Dallas, Texas to Defendant Ray Johnson. It is suspected that Ray Johnson, a stranger is the person at the City of Dallas who filed Code Enforcement cases against Ms. Griggs and other property owners in that area (and later tried to trick other neighbors out of their property); PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE LOT 5 OF CARVER HEIGHTS ADDITION, AN ADDITON TO THE CITY OF DALLAS SITUATED IN CITY BLOCK 7/6889 IN THE CITY OF DALL, DALLAS COUNTY, TEXAS AS SHOWN BY DEED RECORDED IN VOLUME 2005024 PAGE 3563 OF THE DEED RECORDS OF DALLAS COUNTY, TEXAS AND MORE COMMONLY ADDRESSED AS 5846 PLUM DALE ROAD, DALLAS, DALLAS COUNTY, TEXAS VI. THE DECLARATION OF NELDA JOYCE JOHNSON GRIGGS SUPPORTS THE REINSTATEMENT (ATTACHED SEPARATELY). The declaration states it more generally, but Plaintiff was basically scared to death for her life (although she reacted with a lot of courage) because of almost non stop serious health threats that she did expect on the front end — this most likely results in an “incapacity” tolling of issues as well as the “discovery rule” that Defendant did not notify Plaintiff of his fraudulent deed and Plaintiff certainly did not receive a big check from Defendant. Specifics regarding various medical scares - She was dying and fighting cancer and other aggressive diseases when the forged deed was apparently filed. Since she was expecting to die within a year, etc. In 2000-2002 Plaintiff was on the “heart transplant list” because of a defect in her heart resulted in damages to the tissue of the heart and that caused her to collapse (upon Baylor’s recommendation). Plaintiff then had to go on a “trial medication” that appeared to help and the initial trials worked out pretty well — i.e. the PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE drug was approved. Plaintiff dealt with breast cancer for about 5 years starting closer to 2009. Plaintiff had two strokes AFTER Forged deeds are void/nullities. Plaintiff affirms that she did not sign the deed that allegedly would give a property interest to Ray Johnson. Cc The forgers messed up and used the wrong married name, meaning that just like the attached Child Support documents from 2004 to 2006, Ms. Griggs went by Mrs. Griggs when married to second husband, Mr. Griggs and would not have signed with Mr. Johnson as “Mrs. Johnson” in 2004 when she was married to Griggs. A comparison of Ms. Grigg’s signatures to the incorrect, “Ms. Johnson” also suggest that a different person, with a different signature is signing and Ms. Griggs testified that she is the owner of the property and provided a copy of the 1992 divorce from Johnson (affirmed again in 2022) that Ms. Griggs is the owner of the real property after/since the divorce (that it did not transfer to her husband in 1992 and so he would not have signed off of on the Plum Dale Property in 2004, since he would be 0% owner, not 50% Griggs 50% ex husband Brady Johnson, III.). VM THISINTEREST OF JUSTICE, ANDINNOF MADETODELAN. PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE This motion is not filed to delay or waste time. No party is prejudiced by its filing. There is a real risk that if this case is not reinstated that other people could be victims, too, because without a record and/or Lis Pendens filed, other purchasers or renters may be deceived by the forged 2005 deed and pay money for bad title. Forged deeds have no title-passing powers (are a nullity/void), so there is a great interest in promoting justice by preventing fraud. Additionally, as a person who was very ill, Plaintiff has a legitimate interest in a determination as to whether a city official tried to take advantage of her or her family name. VIII. PRAYER Plaintiff prays that this Court will set the Motion to Reinstate for a Hearing, reinstate the case and have a real final trial on the pled cause of actions as well as allow Plaintiffto amend the pleadings to allege a cloud on title, declaratory judgment, fraud, etc., with the discovery rule and incapacitation pled, since Plaintiff was told that she would died very soon from one of several diseases and spent 15 -20 years taking very extreme treatments to cancers, etc. Plaintiff promises that Plaintiff's counsel will make this case very easy to understand. Respectfully submitted, Ciarochi Law Firm,PLLC /s/ Jason Charles Ciarochi Jason Charles Ciarochi State Bar No. 24012424 P. O. Box 29256 Dallas, Texas 75229 (214) 642-2424 (214) 242-2791 (£)(call first) PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE Jason@ciarochilaw.com ATTORNEY FOR NELDA JOYCE JOHNSON GRIGGS CERTIFICATE OF SERVICE AND CONFERENCE Pursuant to the TRCP, true and correct copies are served via on 6.5.23. THERE WAS NOT ENOUGH TIME, COMING INTO THIS CASE AFTER FINISHING A WEEK LONG ARBITTATION WITH 10 ATTRONEYS TO CONFER, BUT I WILL CONFER BEFORE SETTING FOR A HEARING. /s/ Jason Charles Ciarochi Jason Charles Ciarochi HEARING FIAT It is hereby ordered that PLAINTIFF’S MOTION TO REINSTATE CASE shall be heard in the Courtroom of the 134" State District Court, Honorable Dale Tillery Presiding, off of Commerce Street, Dallas Texas 75201 in Dallas County Texas, on the _ _ day of [circle one] JUNE / JULY, 2023. Signed on this day of June, 2023. JUDGE PRESIDING NOTE THIS HEARING NEEDS TO OCCUR BEFORE JULY 15, 2023 PLAINTIFF’S FIRST AMENDED MOTION TO REINSTATE IMAGE SUMMARY < Prev Doc Next Doc > ® | 1 of 2 @ Add To Cart AGL ancue98826 2s Notice of Child Support Lie (Name/Addess oF recorderor set holder) ou BRADY JOHNSON 1 §) (Mame. AdtesvDOB, SSN) (MC2 KINNEY CYPRESS HL PX 75071-3708 Dow 421 SSN FR OFFICE OF THE ATTORNEY GENERAL VID Agency (Claman (CHILD SUPPORT UN 12221 § WALTON WALKER BLVD, s 1 DALLAS. 1X 18236 “TelepieneNo. 214)330-591, “oll Free |(80)687-529), Fa No. (21493392368 ot NEL a Gn (Office ofthe Anomney [NLDA JOYCE jgnment GRIGCS)fom IV. Case Number “This en ress fom child soppy "751/2006 wy 254TH DISTRICT COURT. DALLAS COUNTY, ‘TEXASin rbona umber 9205987 As of 10212006 the we) Judge inthe amount oF $20,354.03. This agent may be subject ‘ners. =oKS y ot pid when du are gre that read othe len amount. This Te. stiches SOs ee J ea ear personal popsty of the abevesnamed obligor which is oete or exiting within the tatocount Fe inelodingry peopeny specifically described below. Specific description of rope: Page tof? Le. > of 2 AOC oncoe98826 ame Notice of Child Support Lien (NameiAdess ofrecorderor eset holder) opLicor: BRADY JOHNSON 1 (ame, Addres'DOB, SSN) 2 CYPRESS HL (MC KINNEYPX 75071-3708 Dow 421 SSN: & f QM (OFFICE OF THE ATTORNEY GENERAL (QV-D Ageney ‘Claimant (CHILD SUPPORT UN £2221 § WALTON WALKER BLVD, s 1 DALLAS, 1x 18236 “TelepioneNo. 214)330-591, “oll ree 1(80)687-829), Fe No. (214)339.2368 ot A NELDA JOYCE GRI oft re sti Ass & [NELDA JOYCEassignment GRIGCS)fom IV-D Case Number: “This ien ress fom child soppy ‘TEXASin rbona umber 9205987 © "51/2006 wy 254TH DISTRICT COURT. DALLAS COUNTY, 5: A of 10272006, the oblige LD) reer ant ‘eters. De Prospect ot pid when du, are gre that read othe len amount This Te stiches J ea enor personal popsty of the abevesamed obligor which is loeted or exiting within the tatecount Fe ineloding any peopenty specifically described below. ‘Specific description af rope: Ri Paget? To th ee 86> s -- wees - wee = of 2 AOC rancue98806 ame Notice of Child Support Lien (NameiAdess ofrecorderor eset holder) ou © BRADY JOHNSON I (ame, AddressDOB, SSN) (MCU2 KINNEY CYPRESS HL PX 75071-3708 Dow 421 SSN: & FROM: OFFICE OF THE ATTORNEY GENERAL V-D Agoney /Claimant) (CHILD SUPPORT UN £2221 § WALTON WALKER BLVD, s 1 DALLAS, 1X 18236 “TelepcneNo. 214)330-4591, “oll Free |(80)687-829), Fx No. (214)339.2368 ot A NELDA JOYCE GRI oft re cations & [NELDA JOYCE inert GRIGCS)fom IV-D Case Number: “This ies resus fom child soppy ‘TEXASin rpona umber 9205987 © "51/2006 wy 254TH DISTRICT COURT. DALLAS COUNTY, A of 10272006, the oblige Judgont nthe amount oF $20,354.03. This jagment may be subject ‘meres. Prospect ot pid when du, are gre that te ad othe len amount. This Te stiches J ea ear personal popsty of the abevesamed obligor which is loeted or exiting within the Statocount Fe inelodingany peopenty specifically described below. ‘Specific desertion f prope: Paget? ee 86> IMAGE SUMMARY < Prev Doc | Next Doc > | 1 of 2 Add To Cart WARRANTY DEED “THE STATEOF TEXAS am ‘COUNTY OF DAL AS. “Tul BRADY JOMNSON M1 Sts& NELDA. 100 (DOLLARS) exh enof Dal, of Tan inh vam RAY JOLINSOR, here calcd GRANT: chin id eve Ged Sld nd Convey an“eal Selcr nd Cae,te ‘tosUtena!opal hig ra atc ot WAY ofJOHNSON sce lowe oe. LEGAL DESCRIPTION: io Das, Ten Map(IGHTS or Pat ADDITION, a Addin tthe ecard of Balin’ Coun, Teas TOHAVE AND; opt nr ns tery bares fGRANTEEsigur wih al Notesbe ng ed VER siDEFREND. sgn alanner pero seg wee cing ad JOHNSON oa Mt 2 26 SELLER: BRADY JOHNSON i & NEEDAJO Washo Celle A Saniora ms us “eee aw hee OF NOTARY Phe TATE OF ENS Soe mel ms02% U3563- Loess hig een re 86} 1 De of 2 Re To th WARRANTY DEED ses ‘THE STATEOF TEXAS wenn ‘COUNTY OF DAL AS om ‘Raby JonNson 100 (DOLLARS) exh eni So Ten inhamid sinTA NGO hoe ced CHARTER oe Gullo Cr dy Gra tem ‘ator preRAY JOHNSON of ad a a sce“eal Slcernd Cae, no lle oe {LEGAL DESCRIPTION: iyo Das, Ten Map(IGHTS ADDITION, Records a Addin tthe ‘Coun, Teas TOHAVE AND, caer naee teeta ate ih anaNees ‘id GRANTEE ns {VER DEFREND. lun hry brute ‘ad prema dng or aha seat ce porn cnr ning ad JOHNSON ont: 2 26 SELLER: BRADY JOHNSON I & NELDA JOM fs — (a chaaon Ta us i EBS &, NOTARY Phe TATE eiaeweente OF ENS 3 twat fe? Of oe Soa ms024 v3563- Loess hig vem ee 86} 1- De of 2 Re To th WARRANTY DEED ses ‘THE STATEOF TEXAS wenn ‘COUNTY OF DALLAS. om ‘Raby Jonsson 100 (DOLLARS) chensi So Ten inhamid sinTAY USO hoe ced CHARTER oe Gel Slo Cra dy ran tem ‘ator peWAY JOHNSON fad a sce“femal Selcrnd Cae, le oe. {LEGAL DESCRIPTION: io Das, Ten Map(IGS ADDITION, Records a Addin tthe ‘Coun, Teas TOHAVE AND, caer nee teeta ateid GRANTEE ih anaNees ns 'VERDEFREND. lun hry brute ‘ad penis dng or aha seat ce pn wc nig ad JOHNSON ont: 2 26 SELLER: BRADY JOHNSON I & NELDA JOM fs — (ie ehason TET us i EBS ios &. NOTARY Phe TATE eiaeweente OF ENS 3 twat fe? Af oe Soar ms02% U3563- Loess hig vem ee 86> IMAGE SUMMARY < Prev Doc Next Doc > ® | 1 of 2 @ Add To Cart (HUTA rancue98806 ame Notice of Child Support Lien (NameiAdess ofrecorderor set holder) opLicor: BRADY JOHNSON 1 §) (ame, Address'DOB, SSN) 2 CYPRESS HL MC KINNEYPX 75071-3708 “a2 SSX: FROM: OFFICE OF THE ATTORNEY GENERAL V-D Ageney /Claimant) (CHILD SUPPORT UN £2221 § WALTON WALKER BLVD, s 1 DALLAS, 1X 18236 “TelepeneNo. 214)330-591, “oll Free 1(80)687-329), Fe No. (214)330.2368 onLicer: NELDA JOYCE GRI (Office ofthe Anomey 'NELDA JOYCEassignment GRIGCS)fom IV-D Case Number: of “This ies ress fom child soppy "51/2006 wy 254TH DISTRICT COURT. DALLAS COUNTY, ‘TEXAS rbona umber 9205987 A of 10272006 the oblige LB) rev santa ‘ees. Prospect ot pid when dare gre that te ad othe len amount. Thi Te. stiches J ea ear personal popsty of the abevesamed obligor which is loeted or exiting within the Statocount Fe ineloding any peopenty specifically described below. ‘Specific description af rope: Paget? JOHNSON NELDA ——— ee — (is > of 2 ACL oncoe98826 ame Notice of Child Support Lien (NameiAdess ofrecorderor set holder) opLicor: BRADY JOHNSON 1 (ame, Addres'DOB, SSN) 2 CYPRESS HL (MC KINNEY PX 75071-3708 Dow 421 SSN: & f QM OFFICE OF THE ATTORNEY GENERAL (QV-D Ageney ‘Claimant (CHILD SUPPORT UN £2221 § WALTON WALKER BLVD, s 1 DALLAS, 1X 15236 “elepieneNo. 214)330-591, “oll ree 1(80)687-529), Fx No. (214)339.2368 ot A NELDA JOYCE GRI ort re sti Ass & [NLDA JOYCEassignment GRIGCS)fom IV-D Case Number: “This en resus fom child soppy ‘TEXASin bona umber 9205987 © 51/2006 wy 254TH DISTRICT COURT. DALLAS COUNTY, 5: A of 10272006, the oblige LB) reeves eta ‘eters. De Prospect ot pid when du, are gre that re ad othe Len amount This Te stiches J ea ear personal popsty of the abevesamed obligor which is oeted or exiting within the Statocount Fe inelodingny peopenty specifically described below. ‘Specific deveiption of rope: Ri Paget? To th JOHNSON NELDA D> =8=6—> s -- wees - wee = of 2 AOC rancue98806 ame Notice of Child Support Lien (NameiAdess ofrecorderor eset holder) ou © BRADY JOHNSON I (ame, AddressDOB, SSN) (MCU2 KINNEY CYPRESS HL PX 75071-3708 Dow 421 SSN: & FROM: OFFICE OF THE ATTORNEY GENERAL V-D Agoney /Claimant) (CHILD SUPPORT UN £2221 § WALTON WALKER BLVD, s 1 DALLAS, 1X 18236 “TelepcneNo. 214)330-4591, “oll Free |(80)687-829), Fx No. (214)339.2368 ot A NELDA JOYCE GRI oft re cations & [NELDA JOYCE inert GRIGCS)fom IV-D Case Number: “This ies resus fom child soppy ‘TEXASin rpona umber 9205987 © "51/2006 wy 254TH DISTRICT COURT. DALLAS COUNTY, A of 10272006, the oblige Judgont nthe amount oF $20,354.03. This jagment may be subject ‘meres. Prospect ot pid when du, are gre that te ad othe len amount. This Te stiches J ea ear personal popsty of the abevesamed obligor which is loeted or exiting within the Statocount Fe inelodingany peopenty specifically described below. ‘Specific desertion f prope: Paget? ee 86> IMAGE SUMMARY < Prev Doc Next Doc > ® | 1 of 3 = @ Add To Cart once 1118 Page 10 A "AUSE NO, 92.5957. GRIGGS NELDA JOYCE INTHE MATTER: ‘THE MARRIAGE, 5 ‘OF JOYCE JOHN: AND BRADY 8 JOHNSON BRADY III JOHNSON,It, JOHNSON JOYCE DALLAS COU! ORDE ° FIN: The C vena ‘cnn a : oe os 1993 i clarified by adding the folowing section: > 18, REAL PROPERTY TO PETITIONER Petone, Neda Joyce riggs forme J the real property losted at Being Block 16889] Lot 5, CARVER HEIGASTS fn Addition tothe Cty of Dallas, “Texas acording tothe Map or Pat fants, Texas more commonly knows as 5846 Plum Dale Rd, Dalle, aspect ofthe Order entered by this Cour ‘on Jone 18, 199, remain TIS ORDERED, Motion wo Clarify Final Decree of Divarce Judgment is GRANTED; LS 3 fe OC Selo 2022. <3 ‘JUDGE PRESIDING Fhe, ete de? LLL =| GRIGGS NELDA JOYCE JOHNSON BRADY III CHILD SUPPORT LIEN 10/25/2006 ® of 3 once 1118 Page ot A Ri (CAUSE NO. 92.5957. GRIGGS NELDA JOYCE INTHE MATTER: ‘THE MARRIAGE, 8 To ‘OF JOYCE JOHN: AND BRADY JOHNSON BRADY III JOHNSON,It, § JOHNSON JOYCE th DALLAS COU ORDE ° FINA The C vena ‘cnn a : oe os 1993 i clarified by adding the folowing section: > 18, REAL PROPERTY, TO PETITIONER etitoner,Nida Joyce Griggs (formetiyJo the real propetylostedat Being Block 16889] Lot 5, CARVER HEIGASTS fn Addition tothe Cty of Dallas, ‘Texas avordng tothe Map or Pat fants, Texas more commonly knows a5 $846 Plum Dale Rd, Dali, Ts aspects ofthe Order entered by this Cour ‘on Jone 18, 199, remain TIS ORDERED, ‘Motion wo Clay Final Decree of Diver Judgment is GRANTED; LS 3 tot OCH? bCC oom 32 ‘JUDGE PRESIDING Fhe, ete a? iove LLL =| NOTICE Preputed by tho State One of Texus for use by Lawyers only. To telect the proper form, fill in blenk 4 HH, sirike out. 1 provitions op intent pela teeras conitibutes the practice of lew. “etene form" can meet all require WARRANTY DEED WITH VENDOR'S LIEN THE STATE OF TEXAS 47s $ 4 10/05/82 KNOW ALL MEN BY THESE PRESENTS: COUNTY OF DALLAS That I, ALBERTA THOMAS, a widow of the County of Dallas and State of Texas for and in consideration of the sum of TEN AND NO/100 ($10.00) --~---~—----- eeee= DOLLARS and other valuable consideration to the undersigned paid by the grantee herein named, the receipt of which is heroby acknowledged, and the further consideration of the execution and delivery by Grantees of their one certain promissory note of eben date herewith, in in the prinicpal sum of TWENTY-EIGHT THOUSAND FIVE HUNDRED ($28,500.00) DOLLARS, payable to the order of Grantor in monthly installments and bearing no interest as therein provided, containing the usual clauses providing for acceleration of maturity and for attorney's fees. DOA gi of DALLgs +\i