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ORIGINAL (
,, 2008-76157
PASADENA INDEPENDENT x IN THE DISTRICT COURT
SCHOOL DISTRICT
vs. x HARRIS COUNTY, TEXAS
JESSE OROPEZA, INDIVIDUALLY x
AND FORMERLY DOING BUSINESS
AS THE STANG SHOP x BQoorcta DISTRICT
PLAINTIFFS ORIGINAL PETITION
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES, PASADENA INDEPENDENT SCHOOL DISTRICT of Harris
County, Texas, a body Politic and Corporate, duly organized and existing under the laws of
Texas, Plaintiff, and on behalf of itself and for the use and benefit of all political subdivision
whose taxes are collected by its tax assessor-collector, and pursuant to Chapter 33, Subchapter C
of the Texas Property Code files this suit for taxes, penalties, interest and costs due it and for
foreclosure of the Constitutional and Statutory liens securing payment thereof against the
following named Defendant(s) who own or claim to own some interest in the property described
below and upon which are delinquent taxes due to Plaintiff, for the year or years, exclusive gf,
penalties, interest and other costs provided by law or legally accruing thereon, as follows:
20
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Name and Address of Defendant Owner(s): m~ ti
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JESSE OROPEZA, INDIVIDUALLY
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AND FORMERLY DOING BUSINESS
AS THE STANG SHOP
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1206 MISSOURI STREET =
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SOUTH HOUSTON, TEXAS 77587-4535
Name and Address of Defendant Lienholder(s):
STATE OF TEXAS, HARRIS COUNTY, HARRIS COUNTY DEPARTMENT
OF EDUCATION, PORT OF HOUSTON AUTHORITY OF HARRIS COUNTY,
HARRIS COUNTY FLOOD CONTROL DISTRICT, THE HARRIS COUNTY
HOSPITAL DISTRICT, SAN JACINTO COMMUNITY COLLEGE DISTRICT
AND CITY OF SOUTH HOUSTON, TEXAS
By Serving: PAUL BETTENCOURT, TAX ASSESSOR-COLLECTOR
1001 PRESTON, SUITE 634
HOUSTON, TEXAS 77002
‘This Instrument is of poor quailty
‘at the time of Imaging
-
Tax Year(s): Taxes:
[TACHED SHIBIT “A” WHICI IN PO [ED HER FOR AL PURPOS
Taxes:
CHED Hl IT “A” V CH IN ORPO TED [EREIN OR JRPO
rroperty Des ption SE [ED tH “a” WHICT INCORPORATED H] [IN FO
01 - Busi Pe
FURNISHINGS/FIXTURES
COMPUTERS, SUPPLIES AND
MACHINERY & EQUIPMENT
ASSESSED UNDER HARRIS COUNTY APPRAISAL
DISTRICT ACCOUNT NO.: 093-076-9
1 Pasadena Independent School District and each political subdivision on whose behalf this
suit is brought are legally constituted and authorized to impose and collect ad valorem
taxes
on property. The tax in the amount stated above was legally imposed on each
separately described property for each year specified and one each person who owned the
propertyon January 1* of the year for which the tax was imposed. The person(s) sued
owned the property or owned an interest in the property when the suit was filed. The tax
was imposed in Harris County, Texas.
2. The tax is delinquent, in addition to the taxes stated in attached Exhibit “A”, penalties
and interest are due and continue to accrue. Costs are due for reasonable expenses in
determining the name, identity, and location of necessary parties and in procuring
necessary legal descriptions of the property on which the delinquent tax is due and
interest due, and for all usual court costs. Plaintiff seeks to recover attorney’s fees of 15
percent of the total amount of taxes, penalties and interest due. In addition, Plaintiff
claims the expenses of foreclosure sale as costs.
3. Plaintiff asserts a lien on each separately described property to secure the payment of all
taxes, penalties, interest and costs due and seeks foreclosure of the lien. All things
required by law to be done have been done property by the appropriate officials, and the
undersigned attorney is legally authorized to prosecute the suit on behalf of Plaintiff.
Plaintiff has given notice of the filing of this petition to the State of Texas, the County of
Harris, and all other taxing agencies, if any, as required by law. All parties to this suit
shall take notice that claims not only for any taxes which were delinquent on the property
at the time suit was filed, but also for all taxes becoming delinquent thereon and at any
time thereafter, and all interest, penalties, fees, expenses and costs allowed by law
thereon, shall be recovered without further notice or citation
to any parties
in this suit.
5. Plaintiff seeks personal judgment against Defendant(s) establishing the total amount of all
taxes, penalties, interest, costs, expenses, attorney’s fees, and costs of court. Plaintiff
does not seek personal judgment against Defendant Lienholder(s), if any. Plaintiff seeks
foreclosure of its tax lien against Defendant and Defendant Lienholder(s) if any.
Defendant Lienholders who are taxing units are notified that they must set up their tax
claims in this suit for recovery of their delinquent ad valorem taxes due on the property or
the court’s judgment shall reflect extinguishment of their liens, pursuant to TEX. TAX
CODE ANN § 33.44 (Vernon 1992).
WHEREFORE, Plaintiff requests personal judgment against the Defendant(s) owning
the property as of January 1" of each year these taxes were assessed, for the total amount of all
taxes, penalties, interest, costs, expenses, attorney’s fees, and costs of court that may be or
become legally due and owing, and requests judgment against Defendant(s) and Defendant
Lienholder(s) for foreclosure of the lien and payment of all taxes, penalties, interest, costs,
expenses, attorney’s fees, cost of court and other charges or expenses that are due or will become
due and that are secured by the lien, for extinguishment of tax liens of taxing units who are made
parties to this suit but who fail to file in this case their claims for delinquent taxes, for an order
that the property be sold to satisfy the judgment, and for all other relief to which it may be
entitled.
Respectfully submitted,
DEXTER D. JOYNER
ATTORNEY FOR PLAINTIFF,
PASADENA INDEPENDENT
SCHOOL DISTRICT
4701 Preston
Pasadena, Texas 77505
(281) 991-6095; Fax: (281) 991-6012
State Bar No.: 11039000
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> ORIGINAL ( ,, 2008-76157 PASADENA INDEPENDENT x IN THE DISTRICT COURT SCHOOL DISTRICT vs. x HARRIS COUNTY, TEXAS JESSE OROPEZA, INDIVIDUALLY x AND FORMERLY DOING BUSINESS AS THE STANG SHOP x BQoorcta DISTRICT PLAINTIFFS ORIGINAL PETITION TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES, PASADENA INDEPENDENT SCHOOL DISTRICT of Harris County, Texas, a body Politic and Corporate, duly organized and existing under the laws of Texas, Plaintiff, and on behalf of itself and for the use and benefit of all political subdivision whose taxes are collected by its tax assessor-collector, and pursuant to Chapter 33, Subchapter C of the Texas Property Code files this suit for taxes, penalties, interest and costs due it and for foreclosure of the Constitutional and Statutory liens securing payment thereof against the following named Defendant(s) who own or claim to own some interest in the property described below and upon which are delinquent taxes due to Plaintiff, for the year or years, exclusive gf, penalties, interest and other costs provided by law or legally accruing thereon, as follows: 20 z= a |! : Name and Address of Defendant Owner(s): m~ ti tse JESSE OROPEZA, INDIVIDUALLY oj po AND FORMERLY DOING BUSINESS AS THE STANG SHOP bo aS vf | 1206 MISSOURI STREET = ou SOUTH HOUSTON, TEXAS 77587-4535 Name and Address of Defendant Lienholder(s): STATE OF TEXAS, HARRIS COUNTY, HARRIS COUNTY DEPARTMENT OF EDUCATION, PORT OF HOUSTON AUTHORITY OF HARRIS COUNTY, HARRIS COUNTY FLOOD CONTROL DISTRICT, THE HARRIS COUNTY HOSPITAL DISTRICT, SAN JACINTO COMMUNITY COLLEGE DISTRICT AND CITY OF SOUTH HOUSTON, TEXAS By Serving: PAUL BETTENCOURT, TAX ASSESSOR-COLLECTOR 1001 PRESTON, SUITE 634 HOUSTON, TEXAS 77002 ‘This Instrument is of poor quailty ‘at the time of Imaging - Tax Year(s): Taxes: [TACHED SHIBIT “A” WHICI IN PO [ED HER FOR AL PURPOS Taxes: CHED Hl IT “A” V CH IN ORPO TED [EREIN OR JRPO rroperty Des ption SE [ED tH “a” WHICT INCORPORATED H] [IN FO 01 - Busi Pe FURNISHINGS/FIXTURES COMPUTERS, SUPPLIES AND MACHINERY & EQUIPMENT ASSESSED UNDER HARRIS COUNTY APPRAISAL DISTRICT ACCOUNT NO.: 093-076-9 1 Pasadena Independent School District and each political subdivision on whose behalf this suit is brought are legally constituted and authorized to impose and collect ad valorem taxes on property. The tax in the amount stated above was legally imposed on each separately described property for each year specified and one each person who owned the propertyon January 1* of the year for which the tax was imposed. The person(s) sued owned the property or owned an interest in the property when the suit was filed. The tax was imposed in Harris County, Texas. 2. The tax is delinquent, in addition to the taxes stated in attached Exhibit “A”, penalties and interest are due and continue to accrue. Costs are due for reasonable expenses in determining the name, identity, and location of necessary parties and in procuring necessary legal descriptions of the property on which the delinquent tax is due and interest due, and for all usual court costs. Plaintiff seeks to recover attorney’s fees of 15 percent of the total amount of taxes, penalties and interest due. In addition, Plaintiff claims the expenses of foreclosure sale as costs. 3. Plaintiff asserts a lien on each separately described property to secure the payment of all taxes, penalties, interest and costs due and seeks foreclosure of the lien. All things required by law to be done have been done property by the appropriate officials, and the undersigned attorney is legally authorized to prosecute the suit on behalf of Plaintiff. Plaintiff has given notice of the filing of this petition to the State of Texas, the County of Harris, and all other taxing agencies, if any, as required by law. All parties to this suit shall take notice that claims not only for any taxes which were delinquent on the property at the time suit was filed, but also for all taxes becoming delinquent thereon and at any time thereafter, and all interest, penalties, fees, expenses and costs allowed by law thereon, shall be recovered without further notice or citation to any parties in this suit. 5. Plaintiff seeks personal judgment against Defendant(s) establishing the total amount of all taxes, penalties, interest, costs, expenses, attorney’s fees, and costs of court. Plaintiff does not seek personal judgment against Defendant Lienholder(s), if any. Plaintiff seeks foreclosure of its tax lien against Defendant and Defendant Lienholder(s) if any. Defendant Lienholders who are taxing units are notified that they must set up their tax claims in this suit for recovery of their delinquent ad valorem taxes due on the property or the court’s judgment shall reflect extinguishment of their liens, pursuant to TEX. TAX CODE ANN § 33.44 (Vernon 1992). WHEREFORE, Plaintiff requests personal judgment against the Defendant(s) owning the property as of January 1" of each year these taxes were assessed, for the total amount of all taxes, penalties, interest, costs, expenses, attorney’s fees, and costs of court that may be or become legally due and owing, and requests judgment against Defendant(s) and Defendant Lienholder(s) for foreclosure of the lien and payment of all taxes, penalties, interest, costs, expenses, attorney’s fees, cost of court and other charges or expenses that are due or will become due and that are secured by the lien, for extinguishment of tax liens of taxing units who are made parties to this suit but who fail to file in this case their claims for delinquent taxes, for an order that the property be sold to satisfy the judgment, and for all other relief to which it may be entitled. Respectfully submitted, DEXTER D. JOYNER ATTORNEY FOR PLAINTIFF, PASADENA INDEPENDENT SCHOOL DISTRICT 4701 Preston Pasadena, Texas 77505 (281) 991-6095; Fax: (281) 991-6012 State Bar No.: 11039000