Preview
Electronically Filed
5/1/2024 4:42 PM
Hidalgo County District Clerks
Reviewed By: Victor Castro
CAUSE NO. C-3854-23-M
NORMA DELGADO, E & D AMOR, INC.§ IN THE DISTRICT COURT
D/B/A PALOMA BLANCA ADULT DAY §
CARE, L & N AMOR INC., D/B/A §
PALOMITA BLANCA ADULT DAY §
CARE, AND AMOR D & B LLC, D/B/A §
PALOMA’S PROVIDER SERVICES, §
Plaintiffs, §
§
VS. §
§
MANUEL SALVADOR GARCIA, JR., § HIDALGO COUNTY, TEXAS
INDIVIDUALLY AND D/B/A RELIABLE §
ACCOUNTING AND TAX SERVICES §
A/K/A RELIABLE TAX SERVICES, §
AND PHILIP SARMIENTO, §
INDIVIDUALLY AND D/B/A RELIABLE §
ACCOUNTING AND TAX SERVICES §
A/K/A RELIABLE TAX SERVICES, AND §
PHILIP SARMIENTO D/B/A A&P §
ACCOUNTING AND TAX SERVICES, §
Defendants. § 476TH JUDICIAL DISTRICT
PLAINTIFFS’ SECOND AMENDED PETITION
TO THE HONORABLE JUDGE OF SAID COURT:
COME NOW, NORMA DELGADO, E & D AMOR, INC. D/B/A PALOMA BLANCA
ADULT DAY CARE, L & N AMOR INC., D/B/A PALOMITA BLANCA ADULT DAY CARE,
AND AMOR D & B LLC, D/B/A PALOMA’S PROVIDER SERVICES, Plaintiffs in the above
styled and numbered cause, and file this second amended petition showing the Court as
follows:
DISCOVERY-CONTROL PLAN
1. Plaintiffs intend to conduct discovery under Level 2 of Texas Rule of Civil
Procedure 190.3.
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Hidalgo County District Clerks
Reviewed By: Victor Castro
CLAIM FOR RELIEF
2. Plaintiffs seek monetary relief over $1,000,000.
PARTIES
3. Plaintiff, NORMA DELGADO, is an individual residing in Hidalgo County,
Texas.
4. Plaintiff, E&D AMOR, INC., D/B/A PALOMA BLANCA ADULT DAY CARE,
is a Texas corporation organized and existing under the laws of the State of Texas.
5. Plaintiff, L&N AMOR, INC., D/B/A PALOMITA BLANCA ADULT DAY CARE,
is a Texas corporation organized and existing under the laws of the State of Texas.
6. Plaintiff, AMOR D&B, LLC, D/B/A PALOMA’S PROVIDER SERVICES, is a
Texas limited liability company organized and existing under the laws of the State of
Texas.
7. Defendant, MANUEL SALVADOR GARCIA, JR., INDIVIDUALLY AND
D/B/A RELIABILE ACCOUNTING AND TAX SERVICES A/K/A RELIABLE TAX
SERVICES has already made an appearance in this case and can be served through his
retained counsel
8. Defendant, PHILIP SARMIENTO, INDIVIDUALLY, an individual who is a
resident of Texas, may be served with process in Hidalgo County at:
4800 Dora Lane
McAllen, TX 78504
OR WHEREVER HE MAY BE FOUND
9. Defendant, PHILIP SARMIENTO, D/B/A RELIABLE ACCOUNTING AND
TAX SERVICES A/K/A RELIABLE TAX SERVICES, an individual who is a resident of
Texas, may be served with process in Hidalgo County at:
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Hidalgo County District Clerks
Reviewed By: Victor Castro
4800 Dora Lane
McAllen, Texas 78504
OR WHEREVER HE MAY BE FOUND
10. Defendant, PHILIP SARMIENTO, D/B/A A&P ACCOUNTING AND TAX
SERVICES, an individual who is a resident of Texas, may be served with process in
Hidalgo County at:
4800 Dora Lane
McAllen, Texas 78504
OR WHEREVER HE MAY BE FOUND
JURISDICTION
11. The Court has subject-matter jurisdiction over the lawsuit because the
amount in controversy exceeds this Court’s minimum jurisdictional requirements.
12. The Court has personal jurisdiction over the parties because all parties are
residents of Texas.
VENUE
13. Venue is proper in Hidalgo County under Texas Civil Practice and
Remedies Code section 15.002 because all or a substantial part of the events or
omissions giving rise to the claim occurred in Hidalgo County, Texas.
FACTS
14. On or about September 2017, Plaintiffs became customers of Defendants
MANUEL SALVADOR GARCIA, JR., INDIVIDUALLY (“Garcia”) AND D/B/A RELIABLE
ACCOUNTING AND TAX SERVICES A/K/A RELIABLE TAX SERVICES and PHILIP
SARMIENTO, INDIVIDUALLY (“Sarmiento”) AND D/B/A RELIABLE ACCOUNTING AND
TAX SERVICES A/K/A RELIABLE TAX SERVICES (collectively “Reliable Tax Services”).
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Hidalgo County District Clerks
Reviewed By: Victor Castro
Defendants represented themselves as accountants to Plaintiffs, when in fact they were
not. Rather, Defendants were tax preparers.
15. In October of 2019, Defendant Sarmiento split off from Defendant Garcia,
and started doing business as A&P ACCOUNTING AND TAX SERVICES (“A&P
Accounting”). Plaintiffs followed Defendant Sarmiento to A&P Accounting.
16. Despite Plaintiffs providing the requisite tax payments and documents to all
Defendants for tax filing, Plaintiff NORMA DELGADO, the managing member of the entity
Plaintiffs, discovered on October 8, 2021, that Defendants failed to do any of Plaintiffs
taxes when the Internal Revenue Service advised Plaintiffs that it was seeking back taxes
and penalties for tax years extending back to 2017 (when Plaintiffs first engaged
Defendants’ tax services). Collectively, the IRS is seeking over $1,000,000 in back taxes
and penalties from Plaintiffs due to all Defendants negligence and fraud.
COUNT 1 – NEGLIGENCE
17. All Defendants had a duty to file and pay Plaintiffs taxes to the IRS.
Defendants breached this duty by failing to file and pay the taxes after Plaintiffs submitted
all appropriate documentation and payment to Defendants. Defendants’ breach
proximately caused the following damages to Plaintiffs:
A. Back taxes and penalties owed to the IRS in excess of $1,000,000.
B. As to Plaintiff NORMA DELGADO, mental anguish in the past and future.
COUNT 2 – FRAUD
18. All Defendants made material misrepresentations to Plaintiffs, that they
were accountants and could provide tax and accounting services to Plaintiffs. These
statements were false as all Defendants were not certified public accountants, but rather
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Electronically Filed
5/1/2024 4:42 PM
Hidalgo County District Clerks
Reviewed By: Victor Castro
tax preparers. Additionally, Defendants did not file or pay for Plaintiffs’ taxes to the IRS.
All Defendants acted knowingly or recklessly in making the representations. All
Defendants intended to induce Plaintiffs, by way of these false representations, into
paying for Defendants’ services in addition to the required payment for taxes, which
Defendants had no intention of sending to the IRS, but rather kept the payments to
themselves. Plaintiffs justifiably relied on these representations to Plaintiffs’ detriment.
COUNT 3 – CONVERSION
19. Plaintiffs transferred capital that they legally owned to Defendants for
purposes of preparing and paying her taxes. Instead of paying the taxes, Defendants
exercised dominion and control over the capital to the exclusion of Plaintiffs, and stole
Plaintiffs’ money Plaintiffs intended to pay taxes with. Despite demand to return the
money, Defendants have not returned the money.
COUNT 4 – FRAUDULENT CONCEALMENT
20. Defendants either converted Plaintiffs’ by keeping it for themselves instead
of paying Plaintiffs’ taxes, or failed entirely to properly pay Plaintiffs’ taxes. Despite
knowing this, Defendants assured Plaintiffs were properly filed and paid, and Plaintiff
relied on these deceptions to Plaintiffs’ detriment.
COUNT 5 – BREACH OF FIDUCIARY DUTY
21. Plaintiffs trusted Defendants to properly prepare, file, and pay Plaintiffs
taxes, and provided Defendants with the proper capital to pay the taxes. Accordingly, a
fiduciary duty existed between Plaintiffs and Defendants. Defendants breached this
fiduciary duty to Plaintiffs by either failing to properly prepare, file, and pay Plaintiffs taxes,
or by converting Plaintiffs capital to themselves, resulting in injury to Plaintiffs.
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Electronically Filed
5/1/2024 4:42 PM
Hidalgo County District Clerks
Reviewed By: Victor Castro
DISCOVERY RULE
22. Plaintiffs affirmatively plead the discovery rule in response to any statute
limitations affirmative defenses. Plaintiffs did not discover their injuries/damages resulting
from Defendants’ actions until on or about October 8, 2021, when the Internal Revenue
Service advised that it would be seeking back taxes and penalties for tax years extending
back to 2017.
JURY DEMAND
23. Plaintiffs demand a jury trial and tenders the appropriate fee with this
petition.
OBJECTION TO ASSOCIATE JUDGE
24. Plaintiffs object to the referral of this case to an associate judge for hearing
a trial on the merits or presiding at a jury trial.
PRAYER
25. For these reasons, Plaintiffs ask that the Court issue citation for Defendant
to appear and answer, and that Plaintiffs be awarded a judgment against Defendant for
the following:
a. Actual damages;
b. Prejudgment and postjudgment interest;
c. Court costs;
d. All other relief to which Plaintiffs are entitled.
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Electronically Filed
5/1/2024 4:42 PM
Hidalgo County District Clerks
Reviewed By: Victor Castro
Respectfully submitted,
LAW OFFICE OF
FRANCISCO J. RODRIGUEZ
1111 West Nolana, Suite A
McAllen, Texas 78504
Telephone: (956) 687-4363
Telecopier: (956) 687-6415
By:/s/ Jared Clark
FRANCISCO J. RODRIGUEZ
State Bar No. 17145800
frankr@mcallenlawfirm.com
DANIELLE C. RODRIGUEZ
State Bar No. 24075952
danielle@mcallenlawfirm.com
JARED A. CLARK
State Bar No. 24101626
jared.clark@mcallenlawfirm.com
MELISSA R. CARRANZA
State Bar No. 24051884
LAW OFFICE OF
MELISSA R. CARRANZA
1100 E. Jasmine Ave. STE 201
McAllen, Texas 78501
Telephone: 956-664-0500
Email: melissa@mrclawfirm.com
ATTORNEYS FOR PLAINTIFFS
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Electronically Filed
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Hidalgo County District Clerks
Reviewed By: Victor Castro
CERTIFICATE OF SERVICE
I hereby certify that I served the foregoing document on counsel of record on the
1st day of May, 2024 pursuant to the Texas Rules of Civil Procedure, to wit:
VIA E-FILE SERVICE:
Yusuf S. Ansari
ANSARI LAW, PLLC
5450 NW Central Dr., STE 200
Houston, Texas 77092
Attorney for Defendant Manuel Salvador Garcia Jr., Individually
and d/b/a Reliable Accounting and Tax Services a/k/a Reliable
Tax Services
VIA EMAIL:
Philip Sarmiento
philip_srmnt@yahoo.com
Defendant
/s/ Jared Clark
JARED A. CLARK
8
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Francisco Rodriguez on behalf of Jared Clark
Bar No. 24101626
frankr@mcallenlawfirm.com
Envelope ID: 87294010
Filing Code Description: Amended Filing
Filing Description: Plaintiffs' Second Amended Petition
Status as of 5/2/2024 9:26 AM CST
Associated Case Party: Norma Delgado
Name BarNumber Email TimestampSubmitted Status
Francisco JRodriguez frankr@mcallenlawfirm.com 5/2/2024 8:59:03 AM SENT
Sonia Maupin sonia@mcallenlawfirm.com 5/2/2024 8:59:03 AM SENT
Jared A.Clark jared.clark@mcallenlawfirm.com 5/2/2024 8:59:03 AM SENT
Melissa Carranza melissa@mrclawfirm.com 5/2/2024 8:59:03 AM SENT
Associated Case Party: Manuel Salvador Garcia, Jr, dba Reliable Accounty and Tax
Services aka Reliable Tax Services
Name BarNumber Email TimestampSubmitted Status
Patience Greene patience@ansarilawpllc.com 5/2/2024 8:59:03 AM SENT
Yusuf Ansari yusuf@ansarilawpllc.com 5/2/2024 8:59:03 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
DANIELLE MCALLEN DANIELLE@MCALLENLAWFIRM.COM 5/2/2024 8:59:03 AM SENT
Associated Case Party: Philip Sarmiento, Individually
Name BarNumber Email TimestampSubmitted Status
Philip Sarmiento philip_srmnt@yahoo.com 5/2/2024 8:59:03 AM SENT
Preview
Electronically Filed 5/1/2024 4:42 PM Hidalgo County District Clerks Reviewed By: Victor Castro CAUSE NO. C-3854-23-M NORMA DELGADO, E & D AMOR, INC.§ IN THE DISTRICT COURT D/B/A PALOMA BLANCA ADULT DAY § CARE, L & N AMOR INC., D/B/A § PALOMITA BLANCA ADULT DAY § CARE, AND AMOR D & B LLC, D/B/A § PALOMA’S PROVIDER SERVICES, § Plaintiffs, § § VS. § § MANUEL SALVADOR GARCIA, JR., § HIDALGO COUNTY, TEXAS INDIVIDUALLY AND D/B/A RELIABLE § ACCOUNTING AND TAX SERVICES § A/K/A RELIABLE TAX SERVICES, § AND PHILIP SARMIENTO, § INDIVIDUALLY AND D/B/A RELIABLE § ACCOUNTING AND TAX SERVICES § A/K/A RELIABLE TAX SERVICES, AND § PHILIP SARMIENTO D/B/A A&P § ACCOUNTING AND TAX SERVICES, § Defendants. § 476TH JUDICIAL DISTRICT PLAINTIFFS’ SECOND AMENDED PETITION TO THE HONORABLE JUDGE OF SAID COURT: COME NOW, NORMA DELGADO, E & D AMOR, INC. D/B/A PALOMA BLANCA ADULT DAY CARE, L & N AMOR INC., D/B/A PALOMITA BLANCA ADULT DAY CARE, AND AMOR D & B LLC, D/B/A PALOMA’S PROVIDER SERVICES, Plaintiffs in the above styled and numbered cause, and file this second amended petition showing the Court as follows: DISCOVERY-CONTROL PLAN 1. Plaintiffs intend to conduct discovery under Level 2 of Texas Rule of Civil Procedure 190.3. 1 Electronically Filed 5/1/2024 4:42 PM Hidalgo County District Clerks Reviewed By: Victor Castro CLAIM FOR RELIEF 2. Plaintiffs seek monetary relief over $1,000,000. PARTIES 3. Plaintiff, NORMA DELGADO, is an individual residing in Hidalgo County, Texas. 4. Plaintiff, E&D AMOR, INC., D/B/A PALOMA BLANCA ADULT DAY CARE, is a Texas corporation organized and existing under the laws of the State of Texas. 5. Plaintiff, L&N AMOR, INC., D/B/A PALOMITA BLANCA ADULT DAY CARE, is a Texas corporation organized and existing under the laws of the State of Texas. 6. Plaintiff, AMOR D&B, LLC, D/B/A PALOMA’S PROVIDER SERVICES, is a Texas limited liability company organized and existing under the laws of the State of Texas. 7. Defendant, MANUEL SALVADOR GARCIA, JR., INDIVIDUALLY AND D/B/A RELIABILE ACCOUNTING AND TAX SERVICES A/K/A RELIABLE TAX SERVICES has already made an appearance in this case and can be served through his retained counsel 8. Defendant, PHILIP SARMIENTO, INDIVIDUALLY, an individual who is a resident of Texas, may be served with process in Hidalgo County at: 4800 Dora Lane McAllen, TX 78504 OR WHEREVER HE MAY BE FOUND 9. Defendant, PHILIP SARMIENTO, D/B/A RELIABLE ACCOUNTING AND TAX SERVICES A/K/A RELIABLE TAX SERVICES, an individual who is a resident of Texas, may be served with process in Hidalgo County at: 2 Electronically Filed 5/1/2024 4:42 PM Hidalgo County District Clerks Reviewed By: Victor Castro 4800 Dora Lane McAllen, Texas 78504 OR WHEREVER HE MAY BE FOUND 10. Defendant, PHILIP SARMIENTO, D/B/A A&P ACCOUNTING AND TAX SERVICES, an individual who is a resident of Texas, may be served with process in Hidalgo County at: 4800 Dora Lane McAllen, Texas 78504 OR WHEREVER HE MAY BE FOUND JURISDICTION 11. The Court has subject-matter jurisdiction over the lawsuit because the amount in controversy exceeds this Court’s minimum jurisdictional requirements. 12. The Court has personal jurisdiction over the parties because all parties are residents of Texas. VENUE 13. Venue is proper in Hidalgo County under Texas Civil Practice and Remedies Code section 15.002 because all or a substantial part of the events or omissions giving rise to the claim occurred in Hidalgo County, Texas. FACTS 14. On or about September 2017, Plaintiffs became customers of Defendants MANUEL SALVADOR GARCIA, JR., INDIVIDUALLY (“Garcia”) AND D/B/A RELIABLE ACCOUNTING AND TAX SERVICES A/K/A RELIABLE TAX SERVICES and PHILIP SARMIENTO, INDIVIDUALLY (“Sarmiento”) AND D/B/A RELIABLE ACCOUNTING AND TAX SERVICES A/K/A RELIABLE TAX SERVICES (collectively “Reliable Tax Services”). 3 Electronically Filed 5/1/2024 4:42 PM Hidalgo County District Clerks Reviewed By: Victor Castro Defendants represented themselves as accountants to Plaintiffs, when in fact they were not. Rather, Defendants were tax preparers. 15. In October of 2019, Defendant Sarmiento split off from Defendant Garcia, and started doing business as A&P ACCOUNTING AND TAX SERVICES (“A&P Accounting”). Plaintiffs followed Defendant Sarmiento to A&P Accounting. 16. Despite Plaintiffs providing the requisite tax payments and documents to all Defendants for tax filing, Plaintiff NORMA DELGADO, the managing member of the entity Plaintiffs, discovered on October 8, 2021, that Defendants failed to do any of Plaintiffs taxes when the Internal Revenue Service advised Plaintiffs that it was seeking back taxes and penalties for tax years extending back to 2017 (when Plaintiffs first engaged Defendants’ tax services). Collectively, the IRS is seeking over $1,000,000 in back taxes and penalties from Plaintiffs due to all Defendants negligence and fraud. COUNT 1 – NEGLIGENCE 17. All Defendants had a duty to file and pay Plaintiffs taxes to the IRS. Defendants breached this duty by failing to file and pay the taxes after Plaintiffs submitted all appropriate documentation and payment to Defendants. Defendants’ breach proximately caused the following damages to Plaintiffs: A. Back taxes and penalties owed to the IRS in excess of $1,000,000. B. As to Plaintiff NORMA DELGADO, mental anguish in the past and future. COUNT 2 – FRAUD 18. All Defendants made material misrepresentations to Plaintiffs, that they were accountants and could provide tax and accounting services to Plaintiffs. These statements were false as all Defendants were not certified public accountants, but rather 4 Electronically Filed 5/1/2024 4:42 PM Hidalgo County District Clerks Reviewed By: Victor Castro tax preparers. Additionally, Defendants did not file or pay for Plaintiffs’ taxes to the IRS. All Defendants acted knowingly or recklessly in making the representations. All Defendants intended to induce Plaintiffs, by way of these false representations, into paying for Defendants’ services in addition to the required payment for taxes, which Defendants had no intention of sending to the IRS, but rather kept the payments to themselves. Plaintiffs justifiably relied on these representations to Plaintiffs’ detriment. COUNT 3 – CONVERSION 19. Plaintiffs transferred capital that they legally owned to Defendants for purposes of preparing and paying her taxes. Instead of paying the taxes, Defendants exercised dominion and control over the capital to the exclusion of Plaintiffs, and stole Plaintiffs’ money Plaintiffs intended to pay taxes with. Despite demand to return the money, Defendants have not returned the money. COUNT 4 – FRAUDULENT CONCEALMENT 20. Defendants either converted Plaintiffs’ by keeping it for themselves instead of paying Plaintiffs’ taxes, or failed entirely to properly pay Plaintiffs’ taxes. Despite knowing this, Defendants assured Plaintiffs were properly filed and paid, and Plaintiff relied on these deceptions to Plaintiffs’ detriment. COUNT 5 – BREACH OF FIDUCIARY DUTY 21. Plaintiffs trusted Defendants to properly prepare, file, and pay Plaintiffs taxes, and provided Defendants with the proper capital to pay the taxes. Accordingly, a fiduciary duty existed between Plaintiffs and Defendants. Defendants breached this fiduciary duty to Plaintiffs by either failing to properly prepare, file, and pay Plaintiffs taxes, or by converting Plaintiffs capital to themselves, resulting in injury to Plaintiffs. 5 Electronically Filed 5/1/2024 4:42 PM Hidalgo County District Clerks Reviewed By: Victor Castro DISCOVERY RULE 22. Plaintiffs affirmatively plead the discovery rule in response to any statute limitations affirmative defenses. Plaintiffs did not discover their injuries/damages resulting from Defendants’ actions until on or about October 8, 2021, when the Internal Revenue Service advised that it would be seeking back taxes and penalties for tax years extending back to 2017. JURY DEMAND 23. Plaintiffs demand a jury trial and tenders the appropriate fee with this petition. OBJECTION TO ASSOCIATE JUDGE 24. Plaintiffs object to the referral of this case to an associate judge for hearing a trial on the merits or presiding at a jury trial. PRAYER 25. For these reasons, Plaintiffs ask that the Court issue citation for Defendant to appear and answer, and that Plaintiffs be awarded a judgment against Defendant for the following: a. Actual damages; b. Prejudgment and postjudgment interest; c. Court costs; d. All other relief to which Plaintiffs are entitled. 6 Electronically Filed 5/1/2024 4:42 PM Hidalgo County District Clerks Reviewed By: Victor Castro Respectfully submitted, LAW OFFICE OF FRANCISCO J. RODRIGUEZ 1111 West Nolana, Suite A McAllen, Texas 78504 Telephone: (956) 687-4363 Telecopier: (956) 687-6415 By:/s/ Jared Clark FRANCISCO J. RODRIGUEZ State Bar No. 17145800 frankr@mcallenlawfirm.com DANIELLE C. RODRIGUEZ State Bar No. 24075952 danielle@mcallenlawfirm.com JARED A. CLARK State Bar No. 24101626 jared.clark@mcallenlawfirm.com MELISSA R. CARRANZA State Bar No. 24051884 LAW OFFICE OF MELISSA R. CARRANZA 1100 E. Jasmine Ave. STE 201 McAllen, Texas 78501 Telephone: 956-664-0500 Email: melissa@mrclawfirm.com ATTORNEYS FOR PLAINTIFFS 7 Electronically Filed 5/1/2024 4:42 PM Hidalgo County District Clerks Reviewed By: Victor Castro CERTIFICATE OF SERVICE I hereby certify that I served the foregoing document on counsel of record on the 1st day of May, 2024 pursuant to the Texas Rules of Civil Procedure, to wit: VIA E-FILE SERVICE: Yusuf S. Ansari ANSARI LAW, PLLC 5450 NW Central Dr., STE 200 Houston, Texas 77092 Attorney for Defendant Manuel Salvador Garcia Jr., Individually and d/b/a Reliable Accounting and Tax Services a/k/a Reliable Tax Services VIA EMAIL: Philip Sarmiento philip_srmnt@yahoo.com Defendant /s/ Jared Clark JARED A. CLARK 8 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Francisco Rodriguez on behalf of Jared Clark Bar No. 24101626 frankr@mcallenlawfirm.com Envelope ID: 87294010 Filing Code Description: Amended Filing Filing Description: Plaintiffs' Second Amended Petition Status as of 5/2/2024 9:26 AM CST Associated Case Party: Norma Delgado Name BarNumber Email TimestampSubmitted Status Francisco JRodriguez frankr@mcallenlawfirm.com 5/2/2024 8:59:03 AM SENT Sonia Maupin sonia@mcallenlawfirm.com 5/2/2024 8:59:03 AM SENT Jared A.Clark jared.clark@mcallenlawfirm.com 5/2/2024 8:59:03 AM SENT Melissa Carranza melissa@mrclawfirm.com 5/2/2024 8:59:03 AM SENT Associated Case Party: Manuel Salvador Garcia, Jr, dba Reliable Accounty and Tax Services aka Reliable Tax Services Name BarNumber Email TimestampSubmitted Status Patience Greene patience@ansarilawpllc.com 5/2/2024 8:59:03 AM SENT Yusuf Ansari yusuf@ansarilawpllc.com 5/2/2024 8:59:03 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status DANIELLE MCALLEN DANIELLE@MCALLENLAWFIRM.COM 5/2/2024 8:59:03 AM SENT Associated Case Party: Philip Sarmiento, Individually Name BarNumber Email TimestampSubmitted Status Philip Sarmiento philip_srmnt@yahoo.com 5/2/2024 8:59:03 AM SENT