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ASSESSED
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ENTERED _ ~
F409)
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NO. 2008-76192 ' “RUTED
x4 AD,
Ve ns
nt OF
PASADENA INDEPENDENT IN THE DISTRICT ‘cou
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SCHOOL DISTRICT
oe ik
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VS. HARRIS COUNTY, TEX A'S
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JACK VO 152"? JUDICIAL oisteict %1A
ORIGINAL PETITION IN INTERVENTION
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES SAN JACINTO COMMUNITY COLLEGE DISTRICT, hereinafter
referred to as Intervenor, and files this its Original Petition in Intervention in the above-entitled and
numbered cause in behalf of the Intervenor and for cause of action says:
1. The Intervenor adopts and incorporates herein Plaintiff's original petition and each
amendment thereto.
2. The Defendant(s) are those parties named in Plaintiff's original petition and each
amendment thereto and also the unknown owners, if any, of the personal and/or real property
described in Plaintiff's Original Petition whose names and residences are unknown, and any and all
other persons including all adverse claimants owning or having any legal or equitable interest or lien
upon the said described personal and/or real property, who owned or claimed some interest in said
personal and/or real property on January 1“ of any year for which the tax was imposed or who owned
or claimed some interest in said personal and/or real property at the time of the filing of this suit.
3. There are delinquent taxes justly due and owing to Intervenor for the years and in the
amounts on account no. 3-0676155-00000, as set out in Exhibit “A” hereto attached and madea part
hereof, together with penalties, interest and costs as provided by law and legally accruing thereon.
4. All of said personal and/or real property is located within the boundaries of SAN
JACINTO COMMUNITY COLLEGE DISTRICT, and all said taxes were authorized by law and
have been duly and legally levied and assessed against said personal and/or real property and the
owners thereof and Intervenor now has and asserts a lien on each tract of personal and/or real
property separately assessed and described in Plaintiff's petition to secure payment of all taxes,
penalties, interests, expenses, attorney’s fees and costs due thereon; and all things required by law
to be done have been duly and legally performed by the proper officials.
5. All parties to this suit and intervention shall take notice that claims not only for any taxes
which were delinquent on said personal and/or real property at the time suit was filed, but also taxes
becoming delinquent thereon at any time thereafter, all interest, penalties, fees, expenses and costs
allowed by Jaw thereon and current taxes prorated up to and including the date of judgment, and all
“-
interest, penalties, fees, expenses and costs allowed by law thereon, shall be recovered herein without
further notice or citation to any parties hereto.
6. The attomey whose name is signed hereto is legally authorized and empowered to file and
prosecute this action on behalf of the SAN JACINTO COMMUNITY COLLEGE DISTRICT
and reasonable attorney’s fees in the amount of fifteen/twenty percent (15%/20%) of the total taxes,
penalties and interest recoverable herein have been incurred in the preparation, filing and prosecution
of this suit, for which Intervenor is entitled to recover as provided by law.
WHEREFORE, Intervenor, SAN JACINTO COMMUNITY COLLEGE DISTRICT, prays
judgment against Defendant(s) for the amount of said taxes, including all other taxes to the date of
the judgment herein, together with all penalties, interests, costs, expenses, fees of office and
attomey’s fees that may be or become legally due and owing that are secured by the asserted tax
liens, together with foreclosure of the said tax liens against the personal and/or real property
described in the Plaintiff's petition, and for personal judgment against said Defendant(s) owning said
personal and/or real property on January 1" of each year same was assessed for taxation for the
amount shown to be due on it, save and except any and ail named lienholders against whom
Intervenor seeks no personal liability, and for such other and further relief to which Intervenor may
be entitled.
Respectfully submitted,
Daniel .§ STnooks
DANIEL J. SNOOKS
State Bar No. 18808000
ATTORNEY FOR INTERVENOR
11550 Fuqua, Suite 490
Houston, Texas 77034
(281) 484-2288
CERTIFICATE OF SERVICE
The undersigned certifies that a copy of this pleading has been mailed to all parties of record
or to their attorneys pursuant to Rule 21a. T.R.C.P. on this date: February 3, 2009.
Daniel
~& Frocks
DANIEL J. SNOOKS
me *
on
DELINQUENT TAX STATEMENT SUMMARY
LEO VASQUEZ
HARRIS COUNTY TAX ASSESSOR-COLLECTOR
1001 PRESTON AVE., SUITE 100
HOUSTON, TEXAS 77002
Certified Owner: Legal Description:
VO JACK 1995 BELMONT PREMIER 16X66,
16827 MUESCHKE RD HUD# TRA0224501
CYPRESS, TX 77433-7810 ‘SERIAL# MSB951670SN15335
CAMINO VILLA MHP
2008 Value: $15,787 Legal Acres: 0000
Account No: 306-761-550-0000 CAD: 6000000676155 Parcel Address: 3310 SPACE CENTER BLVD
As of Date: 01/16/2009 Print Date: 01/16/2009 Printed By: SNKVANTASSI
IF PAID IN IF PAID IN IF PAID IN
Base JANUARY _ 2009 FEBRUARY _ 2009 MARCH 2009
Tax Penalties & Penalties & Penalties &
Year |Tax Units Due Interest Total Interest Total Interest Total
[2005 47 531.57] 324.49| 556.06| 524.88] $56.45] $25.26] $56.83]
12006 a7 $31.57) $19.96 SSE.S3) $20.33 $51.90) $20.71 $52.28
12007 47 $22.95} $11.20] $34.15] $11.48) $34.43) ‘$11.75 $34.70)
[2008 47 $25.80} $0.00} $25.80) SLI $27.61 $2.32) $28.12
TOTAL AMOUNT DUE: ‘$111.89 $55.65 $167.54 $58.50 170.39 $60.04 $171.93
Tax Unit Codes:
47 San Jacinto College District
IF YOU ARE 65 YEARS OF AGE OR OLDER OR ARE DISABLED AND THE PROPERTY DESCRIBED IN THIS DOCUMENT IS YOUR RESIDENCE HOMESTEAD,
YOU SHOULD CONTACT THE APPRAISAL DISTRICT REGARDING ANY ENTITLEMENT YOU MAY HAVE TOA POSTPONEMENT
IN THE PAYMENT OF THESE
TAXES.
Partial Statement: Other Years and Tax Units may be due
Se 1
PLEASE CUT AT THE DOTTED LINE AND RETURN THIS PORTION WITH YOUR PAYMENT.
47
Print Date: 01/16/2069
CAD: 6000000676155
tina ang
LEASE Ni UR As UNT NI ER ON YOUR CHECK AND MAKE CHECKS PAYABLE TO:
LEO VASQUEZ
HARRIS COUNTY TAX ASSESSOR-COLLECTOR
P.O. BOX 4622
HOUSTON, TEXAS 77210-4622
If Paid By Amount Due
306-761-550-0000 JAN 2009 $167.54
|FEB 2009 $170.39
IMAR 2009 $171.93
VO JACK
Amount Paid: 5, .—
16827 MUESCHKE RD
CYPRESS, TX 77433-7810
3067615500000" 0508 000026754 000017039 000017193 oooo00000
Preview
a + ASSESSED QS ENTERED _ ~ F409) a NO. 2008-76192 ' “RUTED x4 AD, Ve ns nt OF PASADENA INDEPENDENT IN THE DISTRICT ‘cou © SCHOOL DISTRICT oe ik ae3 VS. HARRIS COUNTY, TEX A'S a< JACK VO 152"? JUDICIAL oisteict %1A ORIGINAL PETITION IN INTERVENTION TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES SAN JACINTO COMMUNITY COLLEGE DISTRICT, hereinafter referred to as Intervenor, and files this its Original Petition in Intervention in the above-entitled and numbered cause in behalf of the Intervenor and for cause of action says: 1. The Intervenor adopts and incorporates herein Plaintiff's original petition and each amendment thereto. 2. The Defendant(s) are those parties named in Plaintiff's original petition and each amendment thereto and also the unknown owners, if any, of the personal and/or real property described in Plaintiff's Original Petition whose names and residences are unknown, and any and all other persons including all adverse claimants owning or having any legal or equitable interest or lien upon the said described personal and/or real property, who owned or claimed some interest in said personal and/or real property on January 1“ of any year for which the tax was imposed or who owned or claimed some interest in said personal and/or real property at the time of the filing of this suit. 3. There are delinquent taxes justly due and owing to Intervenor for the years and in the amounts on account no. 3-0676155-00000, as set out in Exhibit “A” hereto attached and madea part hereof, together with penalties, interest and costs as provided by law and legally accruing thereon. 4. All of said personal and/or real property is located within the boundaries of SAN JACINTO COMMUNITY COLLEGE DISTRICT, and all said taxes were authorized by law and have been duly and legally levied and assessed against said personal and/or real property and the owners thereof and Intervenor now has and asserts a lien on each tract of personal and/or real property separately assessed and described in Plaintiff's petition to secure payment of all taxes, penalties, interests, expenses, attorney’s fees and costs due thereon; and all things required by law to be done have been duly and legally performed by the proper officials. 5. All parties to this suit and intervention shall take notice that claims not only for any taxes which were delinquent on said personal and/or real property at the time suit was filed, but also taxes becoming delinquent thereon at any time thereafter, all interest, penalties, fees, expenses and costs allowed by Jaw thereon and current taxes prorated up to and including the date of judgment, and all “- interest, penalties, fees, expenses and costs allowed by law thereon, shall be recovered herein without further notice or citation to any parties hereto. 6. The attomey whose name is signed hereto is legally authorized and empowered to file and prosecute this action on behalf of the SAN JACINTO COMMUNITY COLLEGE DISTRICT and reasonable attorney’s fees in the amount of fifteen/twenty percent (15%/20%) of the total taxes, penalties and interest recoverable herein have been incurred in the preparation, filing and prosecution of this suit, for which Intervenor is entitled to recover as provided by law. WHEREFORE, Intervenor, SAN JACINTO COMMUNITY COLLEGE DISTRICT, prays judgment against Defendant(s) for the amount of said taxes, including all other taxes to the date of the judgment herein, together with all penalties, interests, costs, expenses, fees of office and attomey’s fees that may be or become legally due and owing that are secured by the asserted tax liens, together with foreclosure of the said tax liens against the personal and/or real property described in the Plaintiff's petition, and for personal judgment against said Defendant(s) owning said personal and/or real property on January 1" of each year same was assessed for taxation for the amount shown to be due on it, save and except any and ail named lienholders against whom Intervenor seeks no personal liability, and for such other and further relief to which Intervenor may be entitled. Respectfully submitted, Daniel .§ STnooks DANIEL J. SNOOKS State Bar No. 18808000 ATTORNEY FOR INTERVENOR 11550 Fuqua, Suite 490 Houston, Texas 77034 (281) 484-2288 CERTIFICATE OF SERVICE The undersigned certifies that a copy of this pleading has been mailed to all parties of record or to their attorneys pursuant to Rule 21a. T.R.C.P. on this date: February 3, 2009. Daniel ~& Frocks DANIEL J. SNOOKS me * on DELINQUENT TAX STATEMENT SUMMARY LEO VASQUEZ HARRIS COUNTY TAX ASSESSOR-COLLECTOR 1001 PRESTON AVE., SUITE 100 HOUSTON, TEXAS 77002 Certified Owner: Legal Description: VO JACK 1995 BELMONT PREMIER 16X66, 16827 MUESCHKE RD HUD# TRA0224501 CYPRESS, TX 77433-7810 ‘SERIAL# MSB951670SN15335 CAMINO VILLA MHP 2008 Value: $15,787 Legal Acres: 0000 Account No: 306-761-550-0000 CAD: 6000000676155 Parcel Address: 3310 SPACE CENTER BLVD As of Date: 01/16/2009 Print Date: 01/16/2009 Printed By: SNKVANTASSI IF PAID IN IF PAID IN IF PAID IN Base JANUARY _ 2009 FEBRUARY _ 2009 MARCH 2009 Tax Penalties & Penalties & Penalties & Year |Tax Units Due Interest Total Interest Total Interest Total [2005 47 531.57] 324.49| 556.06| 524.88] $56.45] $25.26] $56.83] 12006 a7 $31.57) $19.96 SSE.S3) $20.33 $51.90) $20.71 $52.28 12007 47 $22.95} $11.20] $34.15] $11.48) $34.43) ‘$11.75 $34.70) [2008 47 $25.80} $0.00} $25.80) SLI $27.61 $2.32) $28.12 TOTAL AMOUNT DUE: ‘$111.89 $55.65 $167.54 $58.50 170.39 $60.04 $171.93 Tax Unit Codes: 47 San Jacinto College District IF YOU ARE 65 YEARS OF AGE OR OLDER OR ARE DISABLED AND THE PROPERTY DESCRIBED IN THIS DOCUMENT IS YOUR RESIDENCE HOMESTEAD, YOU SHOULD CONTACT THE APPRAISAL DISTRICT REGARDING ANY ENTITLEMENT YOU MAY HAVE TOA POSTPONEMENT IN THE PAYMENT OF THESE TAXES. Partial Statement: Other Years and Tax Units may be due Se 1 PLEASE CUT AT THE DOTTED LINE AND RETURN THIS PORTION WITH YOUR PAYMENT. 47 Print Date: 01/16/2069 CAD: 6000000676155 tina ang LEASE Ni UR As UNT NI ER ON YOUR CHECK AND MAKE CHECKS PAYABLE TO: LEO VASQUEZ HARRIS COUNTY TAX ASSESSOR-COLLECTOR P.O. BOX 4622 HOUSTON, TEXAS 77210-4622 If Paid By Amount Due 306-761-550-0000 JAN 2009 $167.54 |FEB 2009 $170.39 IMAR 2009 $171.93 VO JACK Amount Paid: 5, .— 16827 MUESCHKE RD CYPRESS, TX 77433-7810 3067615500000" 0508 000026754 000017039 000017193 oooo00000