Preview
Electronically Filed
4/8/2024 3:19 PM
Hidalgo County District Clerks
C-1630-24-L Reviewed By: Armando Cantu
Cause No. ____________
Gustavo Alvarado § IN THE DISTRTICT COURT
Plaintiff §
§
VS. § ______JUDICIAL DISTRICT
§
SIERRA TITLE COMPANY INC. §
SERGIO EFRAIN ZAMORA (Borrower) §
MARICRUZ NIETO (Grantor), §
JUAN ESPINOZA (Lender), §
JORDAN KING (Trustee) §
MAYELA CANTU (Escrow Officer) §
DALILA CAMPOS (Notary) §
Defendants § HIDALGO COUNTY, TEXAS
PLAINTIF’S ORIGINAL PETITION,
REQUEST FOR DECLARATORY RELIEF,
APPLICATION FOR
TEMPORARY INJUNCTION
AND MANDATORY PERMANENT INJUNCTION
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES GUSTAVO ALVARADO, hereinafter referred to as
Gustavo, complaining of SIERRA TITLE COMPANY INC., SERGIO EFRAIN
ZAMORA, MARICRUZ NIETO, JUAN ESPINOZA, JORDAN KING, MAYELA
CANTU and DALILA CAMPOS, hereinafter collectively referred to as Defendants.
I.
DISCOVERY PLAN
Gustavo intends to conduct discovery under level 2, pursuant to Rule
190.3 of the Texas Rules of Civil Procedure.
II.
PARTIES
Plaintiff, GUSTAVO ALVARADO, is a resident of the city of Mcallen,
Hidalgo County, Texas.
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Defendant, Sierra Title Company Inc., is a domestic for profit corporation
Reviewed By: Armando Cantu
registered in the State of Texas. It may be served by serving its registered agent at
the following location: John King, 3409 N. 10th Street, Mcallen Texas, 78501, or
wherever he may be found.
Defendant, Sergio Efrain Zamora, is a resident of McAllen, Hidalgo
County, Texas and may be served at 2408 N. 25 ½ St. McAllen Texas 78501, or
where he may be found.
Defendant Maricruz Nieto is a resident of Odessa Texas, Ector County,
Texas and may be served at her residence, 3843 Penbrook St., Apt. 16, Odessa
Texas 79762-6104, or wherever she may be found.
Defendant Juan Espinoza is a resident of Donna, Hidalgo County Texas.
He may be served at 1610 Hester Ave., Donna, Hidalgo County, Texas 78537.
Defendant Jordan King is a resident of McAllen, Hidalgo County, Texas.
He may be served at his home, 7004 N. Cynthia St. Mcallen, Texas 78504 or at
his place of buisness 3409 N. 10th Street, Mcallen Texas, 78501, or wherever he
may be found.
Defendant Mayela Cantu is a resident of Mission, Hidalgo County, Texas.
She may be served at her home, 1925 E. 21st St. Mission, Texas, 78572-3318 or at
her place of buisness 3409 N. 10th Street, Mcallen Texas, 78501, or wherever she
may be found.
Defendant Dalila Campos is a resident of Edinburg, Hidalgo County,
Texas. She may be served at her home, 13805 N. 33rd St. Edinburg, Texas, 78541-
4418 or her place of buisness 3409 N. 10th Street, Mcallen Texas, 78501, or
wherever she may be found.
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Hidalgo County District Clerks
III. Reviewed By: Armando Cantu
VENUE
Venue of this lawsuit is proper in Hidalgo County, Texas pursuant to CPRC
§15.011 and/or because actions for recovery of real property or to quiet title to
real property shall be brought in the county in which all or a part of the of the
property is located. Also, all or a substantial part of this incident giving rise to
this case occurred in Hidalgo County. Tex. Civ. P. & Rem.Code § 15.002(a)(1).
IV.
FACTS
Defendant Maricruz Nieto is/was the owner of the following tract of land:
Property (including any improvements)
Lot 112, CRYSTAL ESTATES PHASE NO. 1, an addition to the city
of Pharr, Hidalgo County, Texas, according to the plat or Map
thereof recorded in Volume 39, Page 126, Map Records of Hidalgo
County, Texas.
On or about April 11, 2023, a warranty deed with Vendor’s Lien was
executed purporting that Gustavo is the Grantee of Defendant Maricruz Nieto
(Attached Exhibit “A”). Dalila Campos notarized the Warranty Deed. Mayela
Cantu acted as the escrow officer and/or closer on the Warranty Deed. Also, on
April 11, 2023, a Deed of Trust was exectuted purporting that Gustavo was the
Borrower, Defendant Jordan King was the Trustee, and Defendant Juan Espinoza
was the Lender and that the above noted property was the property at issue
(Exihibit B). Dalila Campos notarized the Deed of Trust. Mayela Cantu acted as
the escrow officer and closer on the Deed of Trust as well. Sergio Efrain Zamora
is the person who actually borrowed the money.
Gustavo has not purchased or in any way knowingly acquired any interest
or ownership rights in said property. Gustavo does not possess nor has he ever
possessed said property. Gustavo has never sought to own or possess said
property in any manner. Gustavo never signed any documents regarding this
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Hidalgo County District Clerks
property with Defendants for any interest in said property or to borrow moneyBy:
Reviewed orArmando Cantu
be saddled in any way regarding this property. Gustavo has never met or known
Defendant Juan Espinoza, much less borrowed money from him.
On or about March 21, 2024, Gustavo received a letter in the mail from
Defendant Jordan King for Demand of Payment and Notice of Intention to
Accelerate on the above noted deeds (Exhibit C). Gustavo did not borrow money
nor did he receive any money or property from any of the Defendants. Gustavo
did not purchase this property.
V.
DECLARATORY RELIEF
Rights of the parties
Gustavo requests that the Court declare the following:
1. that Gustavo is not the owner of the above referenced property
(Exhibit “A” & “B”);
2. that Gustavo is not the Grantee in the above mentioned
Warranty Deed (Exhibit “A”);
3. that Gustavo is not the buyer in the above referenced Warranty
Deed (Exhibit “A”);
4. that Gustavo is not the Borrower in the above referenced Deed
of Trust (Exhibit “B”);
5. that Gustavo is not liable for any loan, interest on loan or any
monies owed on the alleged transactions (Exhibits “A” & “B”);
6. that Gustavo does not owe payments of any kind pursuant to a
the aforementioned DEED of Trust (Exhibit “B”);
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Hidalgo County District Clerks
7. that none of the Defendants nor anyone else in privity with any
Reviewed By: Armando Cantu
of the Defendant’s can charge loan payments, fees, penalties, or
accelerations to Gustavo;
8. that Gustavo does not owe any payments, charges, penalties or
monies of any kind to any of the Defendants or anyone in privity
with the Defendants;
9. that Gustavo does not owe and cannot be charged with any
warranties on the property at issue to any of the Defendants or
anyone in privity with them.
Gustavo further prays for recovery of reasonable attorney’s fees expended
herein in seeking and obtaining such a declaratory judgment herein.
Gustavo possesses standing to bring this suit.
Gustavo has unjustly been saddled and harrassed with bills pertaining to
property he does not own, did not buy, and money he did not borrow. Gustavo
did not sign any of the documents listed as exhibits herein. Defendants are
unlawfully burdening Gustavo with debts and responsibilities he is not
responsible.
VI.
APPLICATION FOR TEMPORARY INJUNCTION
AND FOR PERMANENT INJUNCTION
Gustavo is not the owner of property. Gustavo did not seek the property at
issue. Gustavo had no intention of buying said property. Gustavo did not sign
the Warranty Deed nor the Deed of Trust. These transactions were done without
Gustavo’s knowledge or consent. Defendants by and through their acts are
attempting to saddle Gustavo with economic burdens he did not seek. Gustavo is
unaware if the grantor of the property knows that these transactions have taken
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place. Gustavo does not want to be exposed to potential liability to the true
Reviewed By: Armando Cantu
owner of the properties for acts that were done without his knowledge or consent.
Gustavo will likely prevail in its suit for Declaratory Relief.
Gustavo is being threatened with notice of intention to acclerate by Jordan
King (Exhibit “C”). Gustavo will suffer imminent and irreparable harm if
Defendants are not enjoined from saddling Gustavo with this false property
transaction (Exhibit “A,” “B,” “C,”). Defendants must be enjoined from
continuing to saddle Gustavo with this false property Warranty Deed and false
Deed of Trust. Gustavo has a substantial likelihood of success on the merits.
Gustavos request that he be restored to the position he was in prior to this
false property transaction. Gustavo requests that he be removed from any all
liability regarding this property transaction.
Gustavo has been damaged and will continue to experience irreparble
injury by Defendants’ conduct. Gustavo has no adequate remedy at law for the
potential economic and legal injuries by Defendants’ actions. The risk of legal
and economic injures and losses are present and continuous. Gustavo has no
adequate remedy at law to protect himself in this false property transaction from
this present and continuing liability.
Defendants should be enjoined from:
10. Making Gustavo the owner/buyer/Grantee/purchaser of the
above referenced property (Exhibit “A” & “B”)
11. Making Gustavo the buyer/grantee in the above referenced
Warranty Deed (Exhibit “A”);
12. Making Gustavo the Borrower in the above referenced Deed of
Trust (Exhibit “B”);
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Hidalgo County District Clerks
13. Making Gustavo liable for any loan, interest on loan or any
Reviewed By: Armando Cantu
monies or penalties owed on the alleged transactions (Exhibits
“A” & “B”);
14. Making Gustavo liable to owe payments of any kind pursuant
to a the aforementioned DEED of Trust (Exhibit “B”);
15. Making Gustavo liable for any loan payments, fees, charges,
penalties, accelerations by any of the Defendants or anyone else
in privity with any of the Defendants;
16. Making Gustavo liable for any warranties on the property at
issue to any of the Defendants or anyone in privity with them.
Upon final hearing, Gustavo prays for permanent injunctive relief,
enjoining Defendants from 1 through 7 above. In contrast to the irreparable
injury to Gustavo in the event that injunctive relief to prevent him from being
saddled with this economic injury and potential exposure to liability, the
potential harm to Defendants is lesser.
IX.
ATTORNEY’S FEES
It was necessary to secure the services of the undersigned attorney to
enforce and protect the rights of Gustavo. Defendants should be ordered to pay
reasonable attorney’s fees under the Declaratory Judgment Act, Texas Civil
Practice and Remedies Code, §§ 37.009 et. seq. Defendants should be further
ordered to pay all other costs of this proceeding.
WHEREFORE, PREMISES CONSIDERED, Gustavo prays that
Defendants be cited to appear as required by law, that a temporary injunction be
entered, and upon final hearing that Gustavo have and recover from Defendants
appropriate declaratory and permanent mandatory injunctive relief, attorney’s
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fees, costs of court, and for such other and further relief, general or special, at law
Reviewed By: Armando Cantu
or in equity, to which Gustavo may show itself justly entitled.
Respectfully submitted,
Efrain Carrera
617 S. 12th Ave.
Edinburg, Texas 78539
(956) 387-0909
(956) 387-0914 Fax
By: /s/ Efrain Carrera
Efrain Carrera
State bar # 24025284
Attorney for Gustavo
(VERIFICATION)
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Hidalgo County District Clerks
Cause No. C-1630-24-L Reviewed By: Armando Cantu
Gustavo Alvarado § IN THE DISTRTICT COURT
Plainnfi §
§
VS. § JUDICIAL DISTRICT
§
SIERRA TITLE COMPANY INC. §
SERGIO EFRAIN ZAMORA (Borrower) §
MARICRUZ NIETO (Grantor), §
JUAN ESPINOZA (Lender), §
JORDAN KING (Trustee) §
MAYELA CANTU (Escrow Officer) §
DALILA CAMPOS (Notary) §
Defendants § HIDALGO COUNTY, TEXAS
PLAINTIFF’S ORIGINAL PETITION
RES QUEST FOR DECLARATORY RELIEF,
APPLICATION FOR
TEMPORARY INJUNCI‘ION
AND MANDATORY PERMANENT INJUNCI‘ION
VERIFICATION
STATE OF TEXAS §
§
COUNTY OF HIDALGO §
Before me, the undersigned notary public, on this day personally appeared Gustavo
Alvarado who, after being duly sworn, deposed under oath that he is over eighteen years of age;
that he has never been convicted of a felony or crime involving moral turpitude; that he is fully
competent, qualified and authorized to execute this Verification; that he has read the above
Plaintiff‘s Original Petition, Request for Declaratory Relief, Application for Temporary Injunction
and Mandatory Permanent Injunction; and that each and every statement of fact contained therein
is true and correct, based on his personal knowledg and on his ast information and belief.
G stav'c')‘
Alvarado
Mé
'1"
3 .
SWORN TO AND SUBSCRIBED before me on the l day of E‘Qn l
2024, to certify which witness my hand and official seal of office.
“um,
II
$399009 ALYSSA NICOLE FUENTES
m '%"3:°’=N°‘3'Y Pumic' s‘a‘e °f Texas Notary Pu ic in and for the State of Texas
‘33:: Comm. Expires 10-02-2024
‘aififflo
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iféfifis
\ Notary ID 132708505
Preview
Electronically Filed 4/8/2024 3:19 PM Hidalgo County District Clerks C-1630-24-L Reviewed By: Armando Cantu Cause No. ____________ Gustavo Alvarado § IN THE DISTRTICT COURT Plaintiff § § VS. § ______JUDICIAL DISTRICT § SIERRA TITLE COMPANY INC. § SERGIO EFRAIN ZAMORA (Borrower) § MARICRUZ NIETO (Grantor), § JUAN ESPINOZA (Lender), § JORDAN KING (Trustee) § MAYELA CANTU (Escrow Officer) § DALILA CAMPOS (Notary) § Defendants § HIDALGO COUNTY, TEXAS PLAINTIF’S ORIGINAL PETITION, REQUEST FOR DECLARATORY RELIEF, APPLICATION FOR TEMPORARY INJUNCTION AND MANDATORY PERMANENT INJUNCTION TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES GUSTAVO ALVARADO, hereinafter referred to as Gustavo, complaining of SIERRA TITLE COMPANY INC., SERGIO EFRAIN ZAMORA, MARICRUZ NIETO, JUAN ESPINOZA, JORDAN KING, MAYELA CANTU and DALILA CAMPOS, hereinafter collectively referred to as Defendants. I. DISCOVERY PLAN Gustavo intends to conduct discovery under level 2, pursuant to Rule 190.3 of the Texas Rules of Civil Procedure. II. PARTIES Plaintiff, GUSTAVO ALVARADO, is a resident of the city of Mcallen, Hidalgo County, Texas. 1 Electronically Filed 4/8/2024 3:19 PM Hidalgo County District Clerks Defendant, Sierra Title Company Inc., is a domestic for profit corporation Reviewed By: Armando Cantu registered in the State of Texas. It may be served by serving its registered agent at the following location: John King, 3409 N. 10th Street, Mcallen Texas, 78501, or wherever he may be found. Defendant, Sergio Efrain Zamora, is a resident of McAllen, Hidalgo County, Texas and may be served at 2408 N. 25 ½ St. McAllen Texas 78501, or where he may be found. Defendant Maricruz Nieto is a resident of Odessa Texas, Ector County, Texas and may be served at her residence, 3843 Penbrook St., Apt. 16, Odessa Texas 79762-6104, or wherever she may be found. Defendant Juan Espinoza is a resident of Donna, Hidalgo County Texas. He may be served at 1610 Hester Ave., Donna, Hidalgo County, Texas 78537. Defendant Jordan King is a resident of McAllen, Hidalgo County, Texas. He may be served at his home, 7004 N. Cynthia St. Mcallen, Texas 78504 or at his place of buisness 3409 N. 10th Street, Mcallen Texas, 78501, or wherever he may be found. Defendant Mayela Cantu is a resident of Mission, Hidalgo County, Texas. She may be served at her home, 1925 E. 21st St. Mission, Texas, 78572-3318 or at her place of buisness 3409 N. 10th Street, Mcallen Texas, 78501, or wherever she may be found. Defendant Dalila Campos is a resident of Edinburg, Hidalgo County, Texas. She may be served at her home, 13805 N. 33rd St. Edinburg, Texas, 78541- 4418 or her place of buisness 3409 N. 10th Street, Mcallen Texas, 78501, or wherever she may be found. 2 Electronically Filed 4/8/2024 3:19 PM Hidalgo County District Clerks III. Reviewed By: Armando Cantu VENUE Venue of this lawsuit is proper in Hidalgo County, Texas pursuant to CPRC §15.011 and/or because actions for recovery of real property or to quiet title to real property shall be brought in the county in which all or a part of the of the property is located. Also, all or a substantial part of this incident giving rise to this case occurred in Hidalgo County. Tex. Civ. P. & Rem.Code § 15.002(a)(1). IV. FACTS Defendant Maricruz Nieto is/was the owner of the following tract of land: Property (including any improvements) Lot 112, CRYSTAL ESTATES PHASE NO. 1, an addition to the city of Pharr, Hidalgo County, Texas, according to the plat or Map thereof recorded in Volume 39, Page 126, Map Records of Hidalgo County, Texas. On or about April 11, 2023, a warranty deed with Vendor’s Lien was executed purporting that Gustavo is the Grantee of Defendant Maricruz Nieto (Attached Exhibit “A”). Dalila Campos notarized the Warranty Deed. Mayela Cantu acted as the escrow officer and/or closer on the Warranty Deed. Also, on April 11, 2023, a Deed of Trust was exectuted purporting that Gustavo was the Borrower, Defendant Jordan King was the Trustee, and Defendant Juan Espinoza was the Lender and that the above noted property was the property at issue (Exihibit B). Dalila Campos notarized the Deed of Trust. Mayela Cantu acted as the escrow officer and closer on the Deed of Trust as well. Sergio Efrain Zamora is the person who actually borrowed the money. Gustavo has not purchased or in any way knowingly acquired any interest or ownership rights in said property. Gustavo does not possess nor has he ever possessed said property. Gustavo has never sought to own or possess said property in any manner. Gustavo never signed any documents regarding this 3 Electronically Filed 4/8/2024 3:19 PM Hidalgo County District Clerks property with Defendants for any interest in said property or to borrow moneyBy: Reviewed orArmando Cantu be saddled in any way regarding this property. Gustavo has never met or known Defendant Juan Espinoza, much less borrowed money from him. On or about March 21, 2024, Gustavo received a letter in the mail from Defendant Jordan King for Demand of Payment and Notice of Intention to Accelerate on the above noted deeds (Exhibit C). Gustavo did not borrow money nor did he receive any money or property from any of the Defendants. Gustavo did not purchase this property. V. DECLARATORY RELIEF Rights of the parties Gustavo requests that the Court declare the following: 1. that Gustavo is not the owner of the above referenced property (Exhibit “A” & “B”); 2. that Gustavo is not the Grantee in the above mentioned Warranty Deed (Exhibit “A”); 3. that Gustavo is not the buyer in the above referenced Warranty Deed (Exhibit “A”); 4. that Gustavo is not the Borrower in the above referenced Deed of Trust (Exhibit “B”); 5. that Gustavo is not liable for any loan, interest on loan or any monies owed on the alleged transactions (Exhibits “A” & “B”); 6. that Gustavo does not owe payments of any kind pursuant to a the aforementioned DEED of Trust (Exhibit “B”); 4 Electronically Filed 4/8/2024 3:19 PM Hidalgo County District Clerks 7. that none of the Defendants nor anyone else in privity with any Reviewed By: Armando Cantu of the Defendant’s can charge loan payments, fees, penalties, or accelerations to Gustavo; 8. that Gustavo does not owe any payments, charges, penalties or monies of any kind to any of the Defendants or anyone in privity with the Defendants; 9. that Gustavo does not owe and cannot be charged with any warranties on the property at issue to any of the Defendants or anyone in privity with them. Gustavo further prays for recovery of reasonable attorney’s fees expended herein in seeking and obtaining such a declaratory judgment herein. Gustavo possesses standing to bring this suit. Gustavo has unjustly been saddled and harrassed with bills pertaining to property he does not own, did not buy, and money he did not borrow. Gustavo did not sign any of the documents listed as exhibits herein. Defendants are unlawfully burdening Gustavo with debts and responsibilities he is not responsible. VI. APPLICATION FOR TEMPORARY INJUNCTION AND FOR PERMANENT INJUNCTION Gustavo is not the owner of property. Gustavo did not seek the property at issue. Gustavo had no intention of buying said property. Gustavo did not sign the Warranty Deed nor the Deed of Trust. These transactions were done without Gustavo’s knowledge or consent. Defendants by and through their acts are attempting to saddle Gustavo with economic burdens he did not seek. Gustavo is unaware if the grantor of the property knows that these transactions have taken 5 Electronically Filed 4/8/2024 3:19 PM Hidalgo County District Clerks place. Gustavo does not want to be exposed to potential liability to the true Reviewed By: Armando Cantu owner of the properties for acts that were done without his knowledge or consent. Gustavo will likely prevail in its suit for Declaratory Relief. Gustavo is being threatened with notice of intention to acclerate by Jordan King (Exhibit “C”). Gustavo will suffer imminent and irreparable harm if Defendants are not enjoined from saddling Gustavo with this false property transaction (Exhibit “A,” “B,” “C,”). Defendants must be enjoined from continuing to saddle Gustavo with this false property Warranty Deed and false Deed of Trust. Gustavo has a substantial likelihood of success on the merits. Gustavos request that he be restored to the position he was in prior to this false property transaction. Gustavo requests that he be removed from any all liability regarding this property transaction. Gustavo has been damaged and will continue to experience irreparble injury by Defendants’ conduct. Gustavo has no adequate remedy at law for the potential economic and legal injuries by Defendants’ actions. The risk of legal and economic injures and losses are present and continuous. Gustavo has no adequate remedy at law to protect himself in this false property transaction from this present and continuing liability. Defendants should be enjoined from: 10. Making Gustavo the owner/buyer/Grantee/purchaser of the above referenced property (Exhibit “A” & “B”) 11. Making Gustavo the buyer/grantee in the above referenced Warranty Deed (Exhibit “A”); 12. Making Gustavo the Borrower in the above referenced Deed of Trust (Exhibit “B”); 6 Electronically Filed 4/8/2024 3:19 PM Hidalgo County District Clerks 13. Making Gustavo liable for any loan, interest on loan or any Reviewed By: Armando Cantu monies or penalties owed on the alleged transactions (Exhibits “A” & “B”); 14. Making Gustavo liable to owe payments of any kind pursuant to a the aforementioned DEED of Trust (Exhibit “B”); 15. Making Gustavo liable for any loan payments, fees, charges, penalties, accelerations by any of the Defendants or anyone else in privity with any of the Defendants; 16. Making Gustavo liable for any warranties on the property at issue to any of the Defendants or anyone in privity with them. Upon final hearing, Gustavo prays for permanent injunctive relief, enjoining Defendants from 1 through 7 above. In contrast to the irreparable injury to Gustavo in the event that injunctive relief to prevent him from being saddled with this economic injury and potential exposure to liability, the potential harm to Defendants is lesser. IX. ATTORNEY’S FEES It was necessary to secure the services of the undersigned attorney to enforce and protect the rights of Gustavo. Defendants should be ordered to pay reasonable attorney’s fees under the Declaratory Judgment Act, Texas Civil Practice and Remedies Code, §§ 37.009 et. seq. Defendants should be further ordered to pay all other costs of this proceeding. WHEREFORE, PREMISES CONSIDERED, Gustavo prays that Defendants be cited to appear as required by law, that a temporary injunction be entered, and upon final hearing that Gustavo have and recover from Defendants appropriate declaratory and permanent mandatory injunctive relief, attorney’s 7 Electronically Filed 4/8/2024 3:19 PM Hidalgo County District Clerks fees, costs of court, and for such other and further relief, general or special, at law Reviewed By: Armando Cantu or in equity, to which Gustavo may show itself justly entitled. Respectfully submitted, Efrain Carrera 617 S. 12th Ave. Edinburg, Texas 78539 (956) 387-0909 (956) 387-0914 Fax By: /s/ Efrain Carrera Efrain Carrera State bar # 24025284 Attorney for Gustavo (VERIFICATION) 8 Electronically Filed 4/8/2024 3:19 PM Hidalgo County District Clerks Cause No. C-1630-24-L Reviewed By: Armando Cantu Gustavo Alvarado § IN THE DISTRTICT COURT Plainnfi § § VS. § JUDICIAL DISTRICT § SIERRA TITLE COMPANY INC. § SERGIO EFRAIN ZAMORA (Borrower) § MARICRUZ NIETO (Grantor), § JUAN ESPINOZA (Lender), § JORDAN KING (Trustee) § MAYELA CANTU (Escrow Officer) § DALILA CAMPOS (Notary) § Defendants § HIDALGO COUNTY, TEXAS PLAINTIFF’S ORIGINAL PETITION RES QUEST FOR DECLARATORY RELIEF, APPLICATION FOR TEMPORARY INJUNCI‘ION AND MANDATORY PERMANENT INJUNCI‘ION VERIFICATION STATE OF TEXAS § § COUNTY OF HIDALGO § Before me, the undersigned notary public, on this day personally appeared Gustavo Alvarado who, after being duly sworn, deposed under oath that he is over eighteen years of age; that he has never been convicted of a felony or crime involving moral turpitude; that he is fully competent, qualified and authorized to execute this Verification; that he has read the above Plaintiff‘s Original Petition, Request for Declaratory Relief, Application for Temporary Injunction and Mandatory Permanent Injunction; and that each and every statement of fact contained therein is true and correct, based on his personal knowledg and on his ast information and belief. G stav'c')‘ Alvarado Mé '1" 3 . SWORN TO AND SUBSCRIBED before me on the l day of E‘Qn l 2024, to certify which witness my hand and official seal of office. “um, II $399009 ALYSSA NICOLE FUENTES m '%"3:°’=N°‘3'Y Pumic' s‘a‘e °f Texas Notary Pu ic in and for the State of Texas ‘33:: Comm. Expires 10-02-2024 ‘aififflo \\‘“ _ iféfifis \ Notary ID 132708505