Preview
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ORIGINAL
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2008-76176
ENTERED
NO. VERIFIED
PASADENA INDEPENDENT x EN THE DISTRICT COURT
SCHOOL DISTRICT
VS. Xx HARRIS COUNTY, TEXAS
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JESUS GARCIA AND JANIE GARCIA x QS supican DISTRICT
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PLAINTIFF’S ORIGINAL PETITION aot: 2
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TO THE HONORABLE JUDGE OF SAID COURT: ok,
NOW COMES, PASADENA INDEPENDENT SCHOOL DISTRICT ofiferis
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County, Texas, a body Politic and Corporate, duly organized and existing under the inv sof, Q,
Texas, Plaintiff, and on behalf ofitself 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 of
penalties, interest and other costs provided by law or legally accruing thereon, as follows:
Name and Address of Defendant Owner(s):
JESUS GARCIA
606 KENTUCKY STREET
SOUTH HOUSTON, TEXAS 77587
JANIE GARCIA
606 KENTUCKY STREET
SOUTH HOUSTON, TEXAS 77587
Name and Address of Defendant Lienhoider{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
Tax Year(s): Taxes:
ATTACHED EXHIBIT “A” WHICH IS INCORPO! ‘ED HERE! L
Taxes:
SEE ATTA‘ DD EXHIB! “A” WHICH IS INCORPORATED HEREIN FOR ALL P! SE:
Property Description: SEE ATTACHED EXHIBIT “A” WHICH IS INCORPORATED HEREIN FOR
ALL PURPOSES
PERSO! PROPERTY
1982 FLEETWOOD 14X67
GRAY/WOODGRAIN HUD#N/A
SER #FL1AC32035442
ASSESSED UNDER HARRIS COUNTY APPRAISAL
DISTRICT ACCOUNT NO.: 600-000-068-2346
Pasadena Independent Schoo! 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
property on 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.
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.
4. 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 ail 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 submitt,
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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Issue Date : 12/18/2008 Statement Of Account
_ Pasadena ISD Tax AszsessorfCollector— ~ - t
This is a statement of taxes paid and due as of 12/18/2008 based upon the tax
records of the Pasadena ISD Tax Assessor/Collector.
Make checks payable to Pasadena ISD
P.O. Box 1318 This document is not a tax certificate and does not absolve a taxpayer from tax
Pasadena, TX 77501-1318 liability
in any way. Should this document be found to be in error, it may be
Ph: (713) 740-0259 Fax: (713) 740-4044 corrected by the coflections office. Responsibility to pay taxes remains with the
i
taxpayer as outfined in the Texas Property Tax Code.
Property information— eee Owner Information
Property 1D: 6000000682346 Owner| 00005148
| Quick-Ref ID : R189370 Value Information GARCIA JESUS & JANIE
Land HS $0.00 606 KENTUCKY
ST
608 KENTUCKY ST 77587 Land NHS ‘$0.00 SOUTH HOUSTON, TX 77587-3208
imp HS $0.00)
Imp NHS $7,969.00 Ownership: 100.00%
1982 FLEETWOOD 14X67 Ag Mkt $0.00
GRAYMVOODGRAIN HUD# Ag Use $0.00
SERIAL#FL1AC32035442, Tim Mkt $0.00)
9.0000 Acres
Tim Use $0.00
HS Cap Adj $0.00)
Assessed $7,969.00)
Entity Year Tax Discount Pal Aity Fee TOTAL
021 107.58 0.00 0.00 0.00 107.58
021 107.58 0.00 2474 19.85 152.17
021 130.13 0.00 45.55 26.36 202.04
Total for current bills if paid by 12/31/2008 : $107.58
Total due on ail bills 12/31/2008 : $461.79
2008 taxes paid for entity 021 $0.00
2008 Total Taxes Paid : $0.00
Exhibit "A"
© 2003 Tyler Technologies, inc. Page 1of1
Preview
* ORIGINAL e4 « 2008-76176 ENTERED NO. VERIFIED PASADENA INDEPENDENT x EN THE DISTRICT COURT SCHOOL DISTRICT VS. Xx HARRIS COUNTY, TEXAS a JESUS GARCIA AND JANIE GARCIA x QS supican DISTRICT « co “ae PLAINTIFF’S ORIGINAL PETITION aot: 2 we TO THE HONORABLE JUDGE OF SAID COURT: ok, NOW COMES, PASADENA INDEPENDENT SCHOOL DISTRICT ofiferis he Te as ay Oo 2,Ey County, Texas, a body Politic and Corporate, duly organized and existing under the inv sof, Q, Texas, Plaintiff, and on behalf ofitself 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 of penalties, interest and other costs provided by law or legally accruing thereon, as follows: Name and Address of Defendant Owner(s): JESUS GARCIA 606 KENTUCKY STREET SOUTH HOUSTON, TEXAS 77587 JANIE GARCIA 606 KENTUCKY STREET SOUTH HOUSTON, TEXAS 77587 Name and Address of Defendant Lienhoider{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 Tax Year(s): Taxes: ATTACHED EXHIBIT “A” WHICH IS INCORPO! ‘ED HERE! L Taxes: SEE ATTA‘ DD EXHIB! “A” WHICH IS INCORPORATED HEREIN FOR ALL P! SE: Property Description: SEE ATTACHED EXHIBIT “A” WHICH IS INCORPORATED HEREIN FOR ALL PURPOSES PERSO! PROPERTY 1982 FLEETWOOD 14X67 GRAY/WOODGRAIN HUD#N/A SER #FL1AC32035442 ASSESSED UNDER HARRIS COUNTY APPRAISAL DISTRICT ACCOUNT NO.: 600-000-068-2346 Pasadena Independent Schoo! 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 property on 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. 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. 4. 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 ail 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 submitt, 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 . « Issue Date : 12/18/2008 Statement Of Account _ Pasadena ISD Tax AszsessorfCollector— ~ - t This is a statement of taxes paid and due as of 12/18/2008 based upon the tax records of the Pasadena ISD Tax Assessor/Collector. Make checks payable to Pasadena ISD P.O. Box 1318 This document is not a tax certificate and does not absolve a taxpayer from tax Pasadena, TX 77501-1318 liability in any way. Should this document be found to be in error, it may be Ph: (713) 740-0259 Fax: (713) 740-4044 corrected by the coflections office. Responsibility to pay taxes remains with the i taxpayer as outfined in the Texas Property Tax Code. Property information— eee Owner Information Property 1D: 6000000682346 Owner| 00005148 | Quick-Ref ID : R189370 Value Information GARCIA JESUS & JANIE Land HS $0.00 606 KENTUCKY ST 608 KENTUCKY ST 77587 Land NHS ‘$0.00 SOUTH HOUSTON, TX 77587-3208 imp HS $0.00) Imp NHS $7,969.00 Ownership: 100.00% 1982 FLEETWOOD 14X67 Ag Mkt $0.00 GRAYMVOODGRAIN HUD# Ag Use $0.00 SERIAL#FL1AC32035442, Tim Mkt $0.00) 9.0000 Acres Tim Use $0.00 HS Cap Adj $0.00) Assessed $7,969.00) Entity Year Tax Discount Pal Aity Fee TOTAL 021 107.58 0.00 0.00 0.00 107.58 021 107.58 0.00 2474 19.85 152.17 021 130.13 0.00 45.55 26.36 202.04 Total for current bills if paid by 12/31/2008 : $107.58 Total due on ail bills 12/31/2008 : $461.79 2008 taxes paid for entity 021 $0.00 2008 Total Taxes Paid : $0.00 Exhibit "A" © 2003 Tyler Technologies, inc. Page 1of1