Preview
~ 99
2006-507 32
diy 99
Stay, 4g
CLEAR CREEK INDEPENDENT SCHOOL IN THE DISTRIEE 1
out 5
DISTRICT § IG:
7
S/ Pi
i
Y,
ous
rnp 6?
gy
VS. § HARRIS COUNTY, oe Say
LISA FREEMAN HODGE \\; )_ JUDICIAL DISTRICT
ASSESSED
PLAINTIFF'S ORIGINAL PETITION
ENTERED: LL
TO THE HONORABLE JUDGE OF SAID COURT: VERIFIED ——————
LLL
COMES NOW, the taxing districts set out below:
CLEAR CREEK INDEPENDENT SCHOOL DISTRICT on behalf of themselves and all taxing
districts for whom they collect. Each is a political subdivision of the State of Texas, each is
legally constituted and authorized to impose and/or collect ad valorem taxes, and each is
hereinafter called "Plaintiff", whether one or more, original or intervenor, and for such cause of
action would show the following:
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE, may
be served as provided by Section 17.091 of the Texas Civil Practice & Remedies Code since
he/she/it owned, had or claimed an interest in property in the State of Texas on the first day of a
tax year for which taxes have not been paid and is not a resident of the State of Texas. Service
may be had on MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS
NOMINEE by serving the Secretary of State of Texas, 1019 Brazos Street, Rudder Building,
Rm. 220, Austin, Travis County, Texas 78701, and a copy forwarded to the said Defendants
home or office address as follows:
1595 SPRING HILL ROAD, SUITE 310
VIENNA, VA 22182
RECORDER’
'S MEM
iment ig. ORANDUM
at the time
of im; quality
I
Discovery is intended to be conducted under Level 2 pursuant to Rule 190 of the Texas
Rules of Civil Procedure. The name(s) and address (es) of Defendant(s) are:
LISA FREEMAN HODGE
10302 ASTIRUA BLVD
HOUSTON, TX 77089
CALVIN HODGE
10302 ASTORIA BLVD
HOUSTON, TX 77089
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE
BY SERVING THROUGH THE SECRETARY OF STATE OF TEXAS
1019 BRAZOS, RUDDER BLDG., ROOM 220
AUSTIN, TX 78701
MILA, INC. DBA MORTGAGE INVESTMENT LENDING ASSOCIATES INC.
BY SERVING ITS REGISTERD AGENT: CT CORPORATION SYSTEM
1021 MAIN STREET SUITE 1150
HOUSTON, TX 77002
Said Defendant(s) currently own or claim an interest in the property hereinafter described
and/or owned the hereinafter described property on the first day of January of each of the years
for which taxes are due and owing.
By way of this suit Plaintiff does not seek personal judgment from MORTGAGE
ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE; MILA, INC. DBA
MORTGAGE INVESTMENT LENDING ASSOCIATES INC. for the tax, penalty, interest,
costs of court or other associated costs in this litigation.
IL.
The taxes in the amounts and for the years shown on Exhibit "A" attached hereto and
incorporated herein were legally imposed on each separately described property and on the
respectiveperson named (if known) who owned the property on January 1 of such years. Such
a *~
taxes are delinquent and owing, along with penalties and interest authorized by law and detailed
on Exhibit "A", and in addition, Plantiff seeks to recover each penalty that is incurred, and all
interest that accrues on delinquent taxes from the date of judgment to the date of sale. The
property is described on Exhibit "A" attached here to.
In addition to the amounts stated above, Plaintiff sues for costs of court, foreclosure sale
expenses and research expenses for determining the name, identity and location of necessary
parties and in procuring necessary legal descriptions of the property, and other costs, all as
authorized by law. Further, should additional taxes, penalties and interest become due against said
property prior to judgment herein, Plaintiff also sues for such additional amounts.
I
Plaintiff would show that all conditions precedent to the right to levy said taxes were
performed as required by law; that all of said taxes were authorized by law; and that all things
required by law have been duly and legally performed by the proper officials.
IV.
Plaintiff would further show that the attorney signing this petition is legally authorized to
prosecute this suit on behalf of the taxing unit and Plaintiff therefore requests attorney fees as
provided by law.
Vv.
Each tract of the said above described real estate and/or item of personal property was, on
January Ist of the aforesaid years and at the time said taxes were imposed, located within the
boundaries of each of said taxing units and within the boundaries of Harris County, Texas. Each
taxing unit asserts a lien on each separately described property listed above to secure the payment
of all taxes, penalties, interest and costs due.
VI.
Defendant(s) shall take notice of all pleas and interventions which may be filed by
Plaintiff or any party intervening,
Vil.
Plaintiff would show that the party or parties who owned the property described above,
on January 1 of the years indicated are indebted to Plaintiff taxing units for said taxes, penalties
and interest, and are liable for all costs herein. Plaintiff seeks personal liability against such
owners, as well as foreclosure of the tax lien on each separately described property. As to all
other Defendants, Plaintiff's action isa proceeding in rem only, whereby Plaintiff seeks to
foreclose the tax lien on each separately described property listed in satisfaction of the taxes,
penalties, interest and all costs due or to become due herein.
WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that Defendant(s) be cited to
appear and answer herein and that on final hearing recover the following:
Personal judgment against such Defendant(s) who owned the property described herein
on January Ist of the years indicated above, for all taxes, penalties, interest, attorney fees,
and costs that are due or will become due;
Foreclosure of the tax liens, issuance of any order of sale and/or execution on the
property described above and payment of all taxes, penalties, interest, and costs that are
due or will become due and that are secured by such tax liens, which tax liens are first,
prior and/or superior to any other interest in said property; and
Such other and further relief to which Plaintiff may be entitle,
RESPEC’ SUBMITTED,
PERDUE, NDON, FIELDER,
COLL! » LLP
-Y G. WISEMAN
SBOT #21816500
JASON L. BAILEY
SBOT #00790253
1235 N. LOOP WEST, #600
HOUSTON, TEXAS 77008
(713) 862-1860
(713) 862-1429 FAX
~
Delinquent and Current Tax Statement
Clear Creek Independent School District
P.O. Box 799
League City, TX 77576
LISA FREEMAN HODGE Taxpayer ID: 8951
10302 ASTIRUA BLVD
HOUSTON, TX 77089
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 TO A POSTPONEMENT IN THE PAYMENT OF THESE TAXES.
[Tax Year |? Tax Due - | Pand! | TotalDue
-]
[Clear Creek independent School District ]
Legal: CLEAR BROOK CRODDING SECTION 4 BLOCK 4, LOT 41, IN-HARRIS COUNTY, TEXAS.
BEING MORE. PARTICULARLY DESCRIBED IN AN INSTRUMENT FILED IN THE HARRIS COUNTY|
CLERK'S OFFICE DEED RECORDS DIVISION, UNDER.CLERK'S FILE NUMBER X965867..
GEO Code: R418857 " Client Pr rty Code:
2004 $548.98) $278.07 $827.05
2005 $2,492.63) $918.53) $3,411.16
Clear Creek Independent School District TOTAL — $4,238.24
Total If Paid By 8/31/2006
Page 1
Preview
~ 99 2006-507 32 diy 99 Stay, 4g CLEAR CREEK INDEPENDENT SCHOOL IN THE DISTRIEE 1 out 5 DISTRICT § IG: 7 S/ Pi i Y, ous rnp 6? gy VS. § HARRIS COUNTY, oe Say LISA FREEMAN HODGE \\; )_ JUDICIAL DISTRICT ASSESSED PLAINTIFF'S ORIGINAL PETITION ENTERED: LL TO THE HONORABLE JUDGE OF SAID COURT: VERIFIED —————— LLL COMES NOW, the taxing districts set out below: CLEAR CREEK INDEPENDENT SCHOOL DISTRICT on behalf of themselves and all taxing districts for whom they collect. Each is a political subdivision of the State of Texas, each is legally constituted and authorized to impose and/or collect ad valorem taxes, and each is hereinafter called "Plaintiff", whether one or more, original or intervenor, and for such cause of action would show the following: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE, may be served as provided by Section 17.091 of the Texas Civil Practice & Remedies Code since he/she/it owned, had or claimed an interest in property in the State of Texas on the first day of a tax year for which taxes have not been paid and is not a resident of the State of Texas. Service may be had on MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE by serving the Secretary of State of Texas, 1019 Brazos Street, Rudder Building, Rm. 220, Austin, Travis County, Texas 78701, and a copy forwarded to the said Defendants home or office address as follows: 1595 SPRING HILL ROAD, SUITE 310 VIENNA, VA 22182 RECORDER’ 'S MEM iment ig. ORANDUM at the time of im; quality I Discovery is intended to be conducted under Level 2 pursuant to Rule 190 of the Texas Rules of Civil Procedure. The name(s) and address (es) of Defendant(s) are: LISA FREEMAN HODGE 10302 ASTIRUA BLVD HOUSTON, TX 77089 CALVIN HODGE 10302 ASTORIA BLVD HOUSTON, TX 77089 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE BY SERVING THROUGH THE SECRETARY OF STATE OF TEXAS 1019 BRAZOS, RUDDER BLDG., ROOM 220 AUSTIN, TX 78701 MILA, INC. DBA MORTGAGE INVESTMENT LENDING ASSOCIATES INC. BY SERVING ITS REGISTERD AGENT: CT CORPORATION SYSTEM 1021 MAIN STREET SUITE 1150 HOUSTON, TX 77002 Said Defendant(s) currently own or claim an interest in the property hereinafter described and/or owned the hereinafter described property on the first day of January of each of the years for which taxes are due and owing. By way of this suit Plaintiff does not seek personal judgment from MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE; MILA, INC. DBA MORTGAGE INVESTMENT LENDING ASSOCIATES INC. for the tax, penalty, interest, costs of court or other associated costs in this litigation. IL. The taxes in the amounts and for the years shown on Exhibit "A" attached hereto and incorporated herein were legally imposed on each separately described property and on the respectiveperson named (if known) who owned the property on January 1 of such years. Such a *~ taxes are delinquent and owing, along with penalties and interest authorized by law and detailed on Exhibit "A", and in addition, Plantiff seeks to recover each penalty that is incurred, and all interest that accrues on delinquent taxes from the date of judgment to the date of sale. The property is described on Exhibit "A" attached here to. In addition to the amounts stated above, Plaintiff sues for costs of court, foreclosure sale expenses and research expenses for determining the name, identity and location of necessary parties and in procuring necessary legal descriptions of the property, and other costs, all as authorized by law. Further, should additional taxes, penalties and interest become due against said property prior to judgment herein, Plaintiff also sues for such additional amounts. I Plaintiff would show that all conditions precedent to the right to levy said taxes were performed as required by law; that all of said taxes were authorized by law; and that all things required by law have been duly and legally performed by the proper officials. IV. Plaintiff would further show that the attorney signing this petition is legally authorized to prosecute this suit on behalf of the taxing unit and Plaintiff therefore requests attorney fees as provided by law. Vv. Each tract of the said above described real estate and/or item of personal property was, on January Ist of the aforesaid years and at the time said taxes were imposed, located within the boundaries of each of said taxing units and within the boundaries of Harris County, Texas. Each taxing unit asserts a lien on each separately described property listed above to secure the payment of all taxes, penalties, interest and costs due. VI. Defendant(s) shall take notice of all pleas and interventions which may be filed by Plaintiff or any party intervening, Vil. Plaintiff would show that the party or parties who owned the property described above, on January 1 of the years indicated are indebted to Plaintiff taxing units for said taxes, penalties and interest, and are liable for all costs herein. Plaintiff seeks personal liability against such owners, as well as foreclosure of the tax lien on each separately described property. As to all other Defendants, Plaintiff's action isa proceeding in rem only, whereby Plaintiff seeks to foreclose the tax lien on each separately described property listed in satisfaction of the taxes, penalties, interest and all costs due or to become due herein. WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that Defendant(s) be cited to appear and answer herein and that on final hearing recover the following: Personal judgment against such Defendant(s) who owned the property described herein on January Ist of the years indicated above, for all taxes, penalties, interest, attorney fees, and costs that are due or will become due; Foreclosure of the tax liens, issuance of any order of sale and/or execution on the property described above and payment of all taxes, penalties, interest, and costs that are due or will become due and that are secured by such tax liens, which tax liens are first, prior and/or superior to any other interest in said property; and Such other and further relief to which Plaintiff may be entitle, RESPEC’ SUBMITTED, PERDUE, NDON, FIELDER, COLL! » LLP -Y G. WISEMAN SBOT #21816500 JASON L. BAILEY SBOT #00790253 1235 N. LOOP WEST, #600 HOUSTON, TEXAS 77008 (713) 862-1860 (713) 862-1429 FAX ~ Delinquent and Current Tax Statement Clear Creek Independent School District P.O. Box 799 League City, TX 77576 LISA FREEMAN HODGE Taxpayer ID: 8951 10302 ASTIRUA BLVD HOUSTON, TX 77089 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 TO A POSTPONEMENT IN THE PAYMENT OF THESE TAXES. [Tax Year |? Tax Due - | Pand! | TotalDue -] [Clear Creek independent School District ] Legal: CLEAR BROOK CRODDING SECTION 4 BLOCK 4, LOT 41, IN-HARRIS COUNTY, TEXAS. BEING MORE. PARTICULARLY DESCRIBED IN AN INSTRUMENT FILED IN THE HARRIS COUNTY| CLERK'S OFFICE DEED RECORDS DIVISION, UNDER.CLERK'S FILE NUMBER X965867.. GEO Code: R418857 " Client Pr rty Code: 2004 $548.98) $278.07 $827.05 2005 $2,492.63) $918.53) $3,411.16 Clear Creek Independent School District TOTAL — $4,238.24 Total If Paid By 8/31/2006 Page 1