On January 10, 2005 a
Answer
was filed
involving a dispute between
City Of Houston,
Harris County,
Harris County Education Department,
Harris County Education District,
Harris County Flood Control District,
Harris County Hospital District,
Houston Community College System,
Houston Independent School District,
Port Of Houston Authority Of Harris County,
and
Dehumidification Technologies,
Garcia, Elaine,
Garcia, Genaro C,
Garcia, Genaro Jr,
Greater East End Manag Distby Serving Tax Assessor Collector Paul Bett,
Harvest Bend Section I Association,
Moore, John Knox,
Unknown Heirs Of Genaro C Garcia,
for TAX SUIT
in the District Court of Harris County.
Preview
RP
a)
Las 1s
CAUSE NO. 2005-01965
HARRIS COUNTY, ET AL IN THE DISTRICT CO’
VS.
FILED Loren
Bren dectece
151* JUDICIAL DISTRICT
Ps
DEC 3.1 2008
Timer 12-31.
| GENARO C. cee OF HARRIS COUNTY, TEXAS
DEFENDANT’S iG Ni
| TO THE HONORABLE JUDGE OF SAID COURT:
i Now comes, Genaro Garcia Jr. (In Rem Only), whose location is unknown, and such
|
| Person’s unknown heirs, successors and assigns, whose identity and location are unknown,
ii
|! unknown owners, such unknown owners’ heirs, successors and assigns, and any and all
other persons, including adverse claimants, owning or having or claiming any legal or
equitable interest in or lien upon the property which is the subject of the delinquent tax
claim in this case who have been named as Defendants in the above-styled cause, and in
answer to Plaintiff's Original Petition filed therein would respectfully show the Court and
jury the following:
L
GENERAL DENIAL
Defendants deny each and every, all and singular, the allegations in Plaintiff's Original
Petition and demands strict proof thereof by a preponderance of the evidence pursuant to
Mahoney & Associates
Atfomeys at Law Texas Rule of Civil Procedure 92.
9601 Katy Freeway
Suite 375
Houston, Texas jL IL
71024-1392 I
11
713-552-1700 COMPLIANCE WITH C.P.R. 30.01
FAX-552-1761
Patrick D. Mahoney, as Attorney Ad Litem appointed by this Court to represent the
interests of Genaro Garcia Jr. (In Rem Only), whose whereabouts are unknown, and such
nd La Laer 208 Ga, GC Ong Ax aon 2 ot
$277219
oe
person’s unknown heirs, successors and assigns, and whose identity and location are unknown,
including unknown owners and such unknown owners’ heirs, successors and assigns, and any
| and all other persons, including adverse claimants, owning or having or claiming any legal or
i
equitable interest in or lien upon the property. As Attorney Ad Litem, Patrick D. Mahoney,
appointed by this Court to represent the interests of such unknown parties as listed above, is
unable to comply with Tex. Civ. Prac. & Rem. Code § 30.014, because the purpose of being
| appointed Attorney Ad Litem is to locate unknown potential Defendants and/or claimants for
the Court and the Plaintiffs, who have been unable to locate said Defendants.
' Til.
i|
PRAYER
1 Wherefore, having fully answered, Defendants respectfully pray for judgment on the Court
| that the Plaintiff take nothing by his suit, for costs, and for such other and further relief to
which they me justly entitled, either at law or in equity.
Respectfully submitted,
MAHONEY & ASSOCIATES
wk
Patrick D. Mahoney
State Bar No. 12844480
9601 Katy Freeway, Suite 375
Houston, Texas 77024
(713) 552-1700
Mahoney & Associates
Law
(713) 552-1761 Facsimile
‘9601 Katy Freeway
‘Suite 375
Houston, Texas Attorney Ad Litem
77024-1392
713-652-1700
FAX.552-176t
(Noid Lae LA Le 2006 Cron Ger CO Aer mae aa 1 pt
CERTIFICATE OF SERVICE
This is to certify that a true and correct copy of the above and foregoing document has been
served upon the following by facsimile or regular mail on this It day of December, 2008.
' Pankaj R. Parmar
Linebarger, Goggan, Blair & Sampson
1301 Travis Street, Suite 300
| Houston, Texas 77002
| (713) 844-3580 Telephone
: (713) 844-3502 Facsimile
| John Knox Moore
; 906 S Mesquite St.
Brady, TX 76825-5822
|
Elaine Garcia
248 Road 3011-B
Dayton, TX 77535
| Roy D. Hailey
| Butler & Hailey
1616 S Voss Rd Ste 500
Houston, TX 77057-2620
| (713) 780-4135 Telephone
| (713) 780-4549 Facsimile
Wy
i
Patrick D. Mahoney
Mahoney
& Associates
Atfomeys
at Law
9801 Katy Freeway
‘Suite 375
Houston, Texas
77024-1382
713-652-1700
FAX-652-1761
(Nd Le Ad Le A Le 20 Garo, Gee CO Ane Comm Ge 12
Mahoney & Associates
Attorneys at Law
9601 Katy Freeway, Suite 375
Houston, Texas 77024-1392
(713)552-1700 % FAX(713)552-1761
‘wow mahoney-associates com
Patrick D. Mahoney & & Board Certified
Xerxes (Zak) K. Patel Commercial Real Estate Law
Beryl Forrest Mazella x, %¥ Residential Real Estate Law
Daniel T. Frayne Texas Board of Legal Specialization
¥ Also Licensed in New York
December 16, 2008
Hon. Judge Landrum
Tax Court DEC 19 2008
201 Caroline, 8" Floor Time:
ite ony, Te
Houston, TX 77002 By.
ee
RE: Ad Litem Cause No. 2005-01965; Harris County, et al vs. Genaro C. Garcia, et al; In the
District Court of Harris County, Texas 151° Judicial District
Dear Hon. Judge Landrum:
Enclosed for filing in the above referenced cause, please find the original and one copy of the
first page of the following documents filed by Defendants:
. Defendant’s Original Answer
. Notice of Location of Defendant
Please file the documents in your customary manner and return a file stamped copy to our office via
the self-addressed stamped envelope.
If you have any questions please contact our office.
Sincerely,
TA Fiat
Derek Fasulo
Law Clerk
Preview
RP a) Las 1s CAUSE NO. 2005-01965 HARRIS COUNTY, ET AL IN THE DISTRICT CO’ VS. FILED Loren Bren dectece 151* JUDICIAL DISTRICT Ps DEC 3.1 2008 Timer 12-31. | GENARO C. cee OF HARRIS COUNTY, TEXAS DEFENDANT’S iG Ni | TO THE HONORABLE JUDGE OF SAID COURT: i Now comes, Genaro Garcia Jr. (In Rem Only), whose location is unknown, and such | | Person’s unknown heirs, successors and assigns, whose identity and location are unknown, ii |! unknown owners, such unknown owners’ heirs, successors and assigns, and any and all other persons, including adverse claimants, owning or having or claiming any legal or equitable interest in or lien upon the property which is the subject of the delinquent tax claim in this case who have been named as Defendants in the above-styled cause, and in answer to Plaintiff's Original Petition filed therein would respectfully show the Court and jury the following: L GENERAL DENIAL Defendants deny each and every, all and singular, the allegations in Plaintiff's Original Petition and demands strict proof thereof by a preponderance of the evidence pursuant to Mahoney & Associates Atfomeys at Law Texas Rule of Civil Procedure 92. 9601 Katy Freeway Suite 375 Houston, Texas jL IL 71024-1392 I 11 713-552-1700 COMPLIANCE WITH C.P.R. 30.01 FAX-552-1761 Patrick D. Mahoney, as Attorney Ad Litem appointed by this Court to represent the interests of Genaro Garcia Jr. (In Rem Only), whose whereabouts are unknown, and such nd La Laer 208 Ga, GC Ong Ax aon 2 ot $277219 oe person’s unknown heirs, successors and assigns, and whose identity and location are unknown, including unknown owners and such unknown owners’ heirs, successors and assigns, and any | and all other persons, including adverse claimants, owning or having or claiming any legal or i equitable interest in or lien upon the property. As Attorney Ad Litem, Patrick D. Mahoney, appointed by this Court to represent the interests of such unknown parties as listed above, is unable to comply with Tex. Civ. Prac. & Rem. Code § 30.014, because the purpose of being | appointed Attorney Ad Litem is to locate unknown potential Defendants and/or claimants for the Court and the Plaintiffs, who have been unable to locate said Defendants. ' Til. i| PRAYER 1 Wherefore, having fully answered, Defendants respectfully pray for judgment on the Court | that the Plaintiff take nothing by his suit, for costs, and for such other and further relief to which they me justly entitled, either at law or in equity. Respectfully submitted, MAHONEY & ASSOCIATES wk Patrick D. Mahoney State Bar No. 12844480 9601 Katy Freeway, Suite 375 Houston, Texas 77024 (713) 552-1700 Mahoney & Associates Law (713) 552-1761 Facsimile ‘9601 Katy Freeway ‘Suite 375 Houston, Texas Attorney Ad Litem 77024-1392 713-652-1700 FAX.552-176t (Noid Lae LA Le 2006 Cron Ger CO Aer mae aa 1 pt CERTIFICATE OF SERVICE This is to certify that a true and correct copy of the above and foregoing document has been served upon the following by facsimile or regular mail on this It day of December, 2008. ' Pankaj R. Parmar Linebarger, Goggan, Blair & Sampson 1301 Travis Street, Suite 300 | Houston, Texas 77002 | (713) 844-3580 Telephone : (713) 844-3502 Facsimile | John Knox Moore ; 906 S Mesquite St. Brady, TX 76825-5822 | Elaine Garcia 248 Road 3011-B Dayton, TX 77535 | Roy D. Hailey | Butler & Hailey 1616 S Voss Rd Ste 500 Houston, TX 77057-2620 | (713) 780-4135 Telephone | (713) 780-4549 Facsimile Wy i Patrick D. Mahoney Mahoney & Associates Atfomeys at Law 9801 Katy Freeway ‘Suite 375 Houston, Texas 77024-1382 713-652-1700 FAX-652-1761 (Nd Le Ad Le A Le 20 Garo, Gee CO Ane Comm Ge 12 Mahoney & Associates Attorneys at Law 9601 Katy Freeway, Suite 375 Houston, Texas 77024-1392 (713)552-1700 % FAX(713)552-1761 ‘wow mahoney-associates com Patrick D. Mahoney & & Board Certified Xerxes (Zak) K. Patel Commercial Real Estate Law Beryl Forrest Mazella x, %¥ Residential Real Estate Law Daniel T. Frayne Texas Board of Legal Specialization ¥ Also Licensed in New York December 16, 2008 Hon. Judge Landrum Tax Court DEC 19 2008 201 Caroline, 8" Floor Time: ite ony, Te Houston, TX 77002 By. ee RE: Ad Litem Cause No. 2005-01965; Harris County, et al vs. Genaro C. Garcia, et al; In the District Court of Harris County, Texas 151° Judicial District Dear Hon. Judge Landrum: Enclosed for filing in the above referenced cause, please find the original and one copy of the first page of the following documents filed by Defendants: . Defendant’s Original Answer . Notice of Location of Defendant Please file the documents in your customary manner and return a file stamped copy to our office via the self-addressed stamped envelope. If you have any questions please contact our office. Sincerely, TA Fiat Derek Fasulo Law Clerk