Jay Cohen v. Midtown Management District, Greater Southeast Management District, Harris County, the Harris County Department of Education, the Port of Houston Authority of Harris County, the Harris County Flood Control District, and the Harris County Hospital District, 01-14-00914-CV

Jay Cohen v. Midtown Management District, Greater Southeast Management District, Harris County, the Harris County Department of Education, the Port of Houston Authority of Harris County, the Harris County Flood Control District, and the Harris County Hospital District

01-14-00914-CV

| Tex. App. | Oct 23, 2015

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Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 10/23/2015 8:19:19 AM CHRISTOPHER A. PRINE Clerk

*1 ACCEPTED 01-14-00914-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 10/23/2015 8:19:19 AM CHRISTOPHER PRINE

CLERK CASE NO. 01-14-00914-CV IN THE COURT OF APPEALS FOR THE FIRST JUDICIAL DISTRICT OF TEXAS HOUSTON, TEXAS JAY COHEN, APPELLANT v. MIDTOWN MANAGEMENT DISTRICT, ET AL, APPELLEES On Appeal from the 133 rd Judicial District Court of Harris County, Texas, Trial Court Case No. 2013-16814 HARRIS COUNTY APPELLEES’ BRIEF LINEBARGER GOGGAN BLAIR & SAMPSON, LLP 4828 Loop Central Drive, Suite 600 Houston, Texas 77081 (713) 844-3400 main phone (713) 844-3504 fax

Edward J. (Nick) Nicholas State Bar No. 14991350 Nick.Nicholas@LGBS.com Anthony W. (Tony) Nims State Bar No. 15031500 Anthony.Nims@LGBS.com ATTORNEYS FOR HARRIS COUNTY APPELLEES

ORAL ARGUMENT REQUESTED

CASE NO. 01-14-00914-CV

JAY COHEN,

APPELLANT

MIDTOWN MANAGEMENT DISTRICT, ET AL,

APPELLEES

IDENTITY OF THE PARTIES AND COUNSEL

“Appellant” Jay Cohen correctly identified the parties, but for purposes of clarity, the Appellees (Plaintiffs) will be referred to as the “Midtown Appellees”, the Appellees (Intervenors) will be referred to as the “Harris County Appellees”, and both will be referred to collectively as the “Appellees”.

*3 INDEX OF AUTHORITIES ............................................................................ iv STATEMENT REGARDING ORAL ARGUMENT ...................................... 1 STATEMENT OF THE CASE ........................................................................ 2 STATEMENT OF FACTS ............................................................................... 4 SUMMARY OF THE ARGUMENT ............................................................... 7 ARGUMENT AND AUTHORITIES ............................................................... 9

I. THE FIRST AND SECOND NUNC PRO TUNC JUDGMENTS WERE PROPERLY ISSUED ................................ 9 A. THE PURPOSE OF A JUDGMENT NUNC PRO TUNC ... 9 B. THE TRIAL COURT’S INHERENT POWER ................... 10 C. THE TRIAL COURT DETERMINES WHAT

JUDGMENT WAS RENDERED ......................................... 10 D. THE TRIAL COURT DETERMINED THAT THE JUDGEMENTS ENTERED DID NOT CORRESPOND TO THE JUDGMENT RENDERED ........ 11 • THE FIRST NUNC PRO TUNC JUDGMENT ................. 11 • THE SECOND NUNC PRO TUNC JUDGMENT ............ 13

II. APPELLANT’S ISSUES HAVE NO MERIT ............................... 15 A. ISSUE NO. 1. APPELLANT’S ISSUE NO. 1 HAS NO MERIT BECAUSE THE FIRST AND SECOND NUNC PRO TUNC JUDGMENTS ARE BASED ON SUFFICIENT EVIDENCE ................................................... 16

ii

B.

*4 ISSUE NO. 2. APPELLANT’S ISSUE NO. 2 HAS NO MERIT BECAUSE IT IS BASED ON A FALSE PREMISES, I.E. THAT THE FINAL JUDGMENT DID NOT AWARD HISD A JUDGMENT AGAINST APPELLANT ........................................................................ 18

C. ISSUE NO. 3. APPELLANT’S ISSUE NO. 3 HAS NO MERIT FOR THE SAME REASON, AND BECAUSE HCCS WAS A NAMED PLAINTIFF TAXING UNIT WHO WAS AWARDED A JUDGMENT AGAINST APPELLANT ................................ 19

III. APPELLANT FAILED TO PROVE ANY REVERSIBLE ERROR OCCURRED, OR THAT THE TRIAL COURT ABUSED ITS DISCRETION ............................. 20

CONCLUSION AND PRAYER FOR RELIEF .............................................. 22 CERTIFICATE OF COMPLIANCE ............................................................... 23 CERTIFICATE OF SERVICE ......................................................................... 23 APPENDIX ...................................................................................................... 24

Tab 1: Harris County’s Original Intervention (SCR2 at 3-6) Tab 1A: Original Intervention Exhibit A – Harris County Appellees’

Certified Tax Records (SCR2 at 7-15) Tab 2: Transcript of November 15, 2013 Final Trial (RR Vol. 1, p. 1-7) Tab 2A: Trial Exhibit A – Harris County Appellees’ Certified Tax Records (RR Vol. 2) iii

INDEX OF AUTHORITIES

*5 Cases Page America’s Favorite Chicken Co. v. Galvan , 897 S.W.2d 874, 877

(Tex.App.-San Antonio 1995, writ denied) .......................................... 11 Andrews v. Koch , 702 S.W.2d 584, 585 (Tex. 1986) ....................................... 9 Barton v. Gillespie , 178 S.W.3d 121, 127 (Tex.App.-Houston

[1 st Dist.] 2005, no pet.) .......................................................................... 17 Batson v. Bentley , 4 S.W.2d 577, 578 (Tex.Civ.App.-Amarillo 1928, no pet.) ..................................................................................................... 12 Burgess v. Burgess , 834 S.W.2d 538, 540 (Tex.App.-Houston [1 st Dist.] 1992, no writ) .................................................................... 10, 15 Carlyle Real Estate Ltd. P’ship-X v. Leibman , 782 S.W.2d 230, 233 (Tex.App.-Houston [1 st Dist.] 1989, no writ.) ........................................ 12 Cire v. Cummings , 134 S.W.3d 835, 838-39 (Tex.2004) ................................. 21 Claxton v. (Upper) Lake Fork Water Control and Imp. Dist. No. 1,

220 S.W.3d 537, 545 (Tex.App.-Texarkana 2006, pet. denied) ...... 16, 17 Coleman v. Zapp , 151 S.W. 1040, 1041 (Tex. 1912) ...................................... 10 Davis v. City of Austin , 632 S.W.2d 331, 333 (Tex. 1982) ............................... 14 Escobar v. Escobar , 711 S.W.2d 230, 231 (Tex. 1986) ............................... 9, 11 Ex parte Hogan , 916 S.W.2d 82, 85 (Tex.App.-Houston [1 st Dist.]

1996, orig. proceeding) .......................................................................... 11 Ferguson v. Naylor , 860 S.W.2d 123 127 (Tex.App.-Amarillo 1993, writ denied) ............................................................................................ 10 iv *6 Fiske v. Fiske , No. 01-03-00048-CV, 2004 WL 1847368, at *5 (Tex.App.-Houston [1 st Dist.] Aug. 19, 2004, no pet.) (mem.op.) ........ 15 Ft. Worth & D.C. Ry. Co. v. Roberts , 81 S.W. 25, 26 (Tex. 1904) ................. 17 Hernandez v. Lope z, 288 S.W.3d 180, 189-90 (Tex.App-Houston

[1 st Dist.] 2009, no pet) ................................................................. 9, 11, 20 In re Barber , 982 S.W.2d 364, 366 (Tex. 1998) .............................................. 21 LaGoye v. Victoria Wood Condominium Ass’n , 112 S.W.3d 777, 783

(Tex.App.-Houston [14 th Dist.] 2003, no pet.) ....................................... 9 Operation Rescue-National v. Planned Parenthood of Houston and Southeast Texas, Inc. , 937 S.W.2d 60, 86 (Tex.App.-Houston [14 th Dist.] 1996, aff’d as modified on other grounds , 975 S.W.2d 546 (Tex. 1998)) .................................................................................... 17

Perry Homes v. Cull , 258 S.W.3d 580, 602 (Tex. 2008) ................................. 21 Pruet v. Coastal States Trading, Inc., 715 S.W.2d 702, 704 (Tex.App.

-Houston [1 st Dist.] 1986, no writ) ................................................... 13, 17 Randle v. Randle , No. 01-96-00459-CV, 1997 WL 7026, at *2 (Tex.App.-Houston [1 st Dist.] 1997, no pet.) (op. per curiam) ....... 10, 11 Riner v. Briargrove Park Prop. Owners, Inc. , 976 S.W.2d 680, 683 (Tex.App.-Houston [1 st Dist.] 1997, no writ) .................................... 13, 16 Sederholm v. Neville , No. 01-12-00215-CV, 2014 WL 2625633, at *3 (Tex.App.-Houston [1 st Dist.] Jun 12, 2014, no pet.) (mem. op.) ........ 20 Shelby v. Shelby , 517 S.W.2d 696, 697-98 (Tex.App.-Houston [1 st Dist.] 1974, writ ref’d n.r.e.) ............................................................................ 10 SLT Dealer Group, Ltd. v. AmeriCredit Fin. Services, Inc., 336 S.W.3d 822, 832-33 (Tex.App.-Houston [1 st Dist.] 2011, no pet.) .................... 15 v *7 Thompson v. Tex. Dept. of Human Resources , 859 S.W.2d 482, 484 (Tex.App.-San Antonio 1993, no writ) .................................................. 11 Unifund CCR Partners v. Villa , 299 S.W.3d 92, 97 (Tex. 2009) .................... 21 Universal Underwriters Ins. Co. v. Ferguson , 471 S.W.2d 28, 29-30

(Tex. 1971) ............................................................................................. 10 Wedgeworth v. Pope , 12 S.W.2d 1045, 1047 (Tex.Civ.App.-Fort Worth 1928, writ ref’d) ..................................................................................... 15 Wood v. Paulus , 524 S.W.2d 749, 755 (Tex.Civ.App.-Corpus Christi 1975, writ ref’d n.r.e.) ............................................................................ 17 Zamora v. Salinas , 422 S.W.2d 249, 251 (Tex.App.-Corpus Christi 1967, writ ref’d n.r.e.) ...................................................................................... 14 Statutes, Regulations & Rules Page T EX . P ROP . T AX . C ODE § 33.47 ......................................................... 5, 14, 15, 21 T EX . R. A PP . P. 9.4(i)(1) ................................................................................... 23 T EX . R. A PP . P. 38.1(d) ...................................................................................... 2 T EX . R. A PP . P. 38.1(g) ..................................................................................... 4 T EX . R. A PP . P. 39 ............................................................................................. 1 T EX . R. A PP . P. 44.1 .......................................................................................... 20

STATEMENT REGARDING ORAL ARGUMENT

*8 The Harris County Appellees request oral argument and believe that the customary time limits should apply. Rule 39, T EX . R. A PP . P. 1

STATEMENT OF THE CASE

*9 The Harris County Appellees object to Appellant’s Statement of the Case in its entirety because it contains argument, is not supported by record references, and discusses alleged and contested facts. (Brief at 8-9). Rule 38.1(d), T EX .R.A PP .P. As a result, the Harris County Appellees offer the following Statement of the Case in the alternative:

Harris County Appellees’ Statement of the Case On March 21, 2013, the Midtown Appellees filed their Original Petition against Appellant. (CR at 4-8, “Petition”) 1 . The Petition sought to recover property taxes allegedly owed by the Appellant. ( Id. ). On June 3, 2013, Appellant filed his Original Answer and asserted a general denial. (CR at 9). On July 26, 2013, the Harris County Appellees filed their Original Intervention (“Intervention”). (SCR2 at 3-6, Appellee’s App. Tab 1). Delinquent Tax Statement Summaries for Appellant’s Real Property 2 were attached to, and incorporated in, the Intervention. (SCR2 at 3- 6 and 7-15, Appellee’s App. Tabs 1 and 1A) (“Delinquent Tax Records”). 1

Citations made herein are to the Original Clerk’s Record (“CR”), the First Supplemental Clerk’s Record (“SCR1”), the Second Supplemental Clerk’s Record (“SCR2”), Volumes 1 and 2 of the Reporter’s Record (“RR Vol. 1” and “RR Vol. 2”, respectively), Appellant’s Appendix (“Appellant’s App. Tab #”), and Appellees’ Appendix (“Appellee’s App. Tab #”). 2

“Real Property” means and includes the real property identified by Harris County Tax Assessor-Collector Account No: (1) 002-146-000-0008 (SCR2 at 7, “Tract 1”), (2) 019-190-000- 0006 (SCR2 at 9-10, “Tract 2”)), (3) 061-168-034-0003 (SCR2 at 11, “Tract 3”), (4) 019-268-000- 0010 (SCR2 at 12-13. “Tract 4”), and (5) 019-203-001-0009 (SCR2 at 14-15. “Tract 5”), (Appellees’ App. Tab 1A).

2 *10 The case was tried in the 133 rd Judicial District Court of Harris County, Texas (“Trial Court”) on November 15, 2013. (RR Vol. 1, p. 1-7 and RR Vol. 2, p. 1, Appellees’ App. Tabs 2 and 2A). On that same day the Trial Court orally rendered Judgment for the Plaintiffs, and then entered a written Final Judgment which awarded Judgment to the “Plaintiff Taxing Units whether Plaintiff(s), Intervenor(s) or Impleaded Plaintiff(s).” (RR Vol. 1, p. 5, l. 24, Appellees’ App. Tab 2; SCR2 at 25-58, Appellant’s App. Tab 1).

Thereafter, on July 25, 2014 and May 21, 2015, the Trial Court issued Orders for Judgment Nunc Pro Tunc, and the First and Second Nunc Pro Tunc Judgments. (SCR2 at 22-91, Appellant’s App. Tab 2 3 and Order; and 98-107, Appellant’s App. Tab 3 4 and Order, respectively).

Appellant filed his Notice of Appeal on November 17, 2014. (CR at 117-19). 3 Appellant refers to this document as the “Revised Second Order of Final Judgment”, but the document is titled “Nunc Pro Tunc Final Judgment”. (Appellant’s App. Tab 2). Therefore Appellees refer to this document as the “First Nunc Pro Tunc Judgment.” 4

Appellant refers to this document as the “Revised Third Order of Final Judgment”, but the document is titled “Nunc Pro Tunc Final Judgment”. (Appellant’s App. Tab 3). Therefore Appellees refer to this document as the “Second Nunc Pro Tunc Judgment.”

STATEMENT OF FACTS

*11 The Harris County Appellees object to Appellant’s Statement of Facts because it is incomplete. Rule 38.1(g), T EX .R.A PP .P. Therefore, the Harris County Appellees offer the following facts as a clarification of, or supplement to, Appellant’s Statement of Facts.

On July 26, 2013, the Harris County Appellees filed their Intervention. (SCR2 at 3-6 and 7-15, Appellees’ App. Tabs 1 and 1A). The Intervention named the Harris County Appellees, including Houston Independent School District (“HISD”) and Houston Community College System (“HCCS”), as the Intervenors. (SCR2 at 3, ¶ I, Appellees’ App. Tab 1). Delinquent Tax Records were attached to the Intervention as Exhibit A, and the Intervention states they are “attached hereto and made a part hereof by reference for all purposes.” (SCR2 at 3-6 and 7-15, Appellees’ App. Tabs 1 and 1A; SCR2 at 4, ¶ III, Appellees’ App. Tab 2). The Delinquent Tax Records list the taxing units which are owed taxes, penalties and interest, and HISD (Tax Unit Code #1) and HCCS (Tax Unit Code #48) are included in the list. (SCR2 at 7- 15, Appellees’ App. Tab 1A).

The case was called to trial on November 15, 2013 but Appellant failed to appear. (RR Vol. 1, p. 1; RR Vol. 1, p. 4, l. 14-25, Appellees’ App. Tab 2). Thereafter, the Midtown Appellees, and then the Harris County Appellees, introduced Delinquent Tax Records into evidence. (RR Vol. 1, p. 5, l. 2-11,

4 *12 Appellees’ App. Tab 2 and RR Vol. 2, Plaintiffs’ Exhibits A and B; RR Vol. 1, p. 5, l. 13-23 and RR Vol. 2, Harris County Exhibits A and B, Appellees’ App. Tabs 2 and 2A).

Pursuant to § 33.47 of T EX . P ROP . T AX C ODE , the Midtown Appellees Exhibit A was prima facie proof that Appellant owed them taxes, penalties and interest. (RR Vol. 2, Plaintiff’s Exhibit B). Likewise, the Harris County Appellees’ Exhibit A proved that Appellant owed them - including HISD and HCCS - taxes, penalties and interest. (RR Vol. 2, Harris County Exhibit A, Appellees’ App. Tab 2A). Furthermore, the amounts identified as being owed to HCCS (Tax Unit Code #48) in Exhibit A, match the amounts listed as being owed to HCCS in the Second Nunc Pro Tunc Judgment. (SCR2 at 100-101, Appellant’s App. Tab 3). 5

After Appellees presented their prima facie cases, the Trial Court orally rendered judgment for the Appellees, and then issued its written Final Judgment. (RR Vol. 1, p. 5, l. 24, Appellees’ App. Tab 2; SCR2 at 25-58, Appellant’s App. Tab 1). The Final Judgment identified both HCCS as an Intervenor, and HISD as a taxing unit. (SCR2 at 25, and 27-28, Appellant’s App. Tab 1).

Thereafter the Trial Court issued an Order finding that the Final Judgment did not match the Judgment rendered because the Final Judgment shows that Appellant 5 See Harris County Appellees’ Exhibit A (RR Vol. 2, Exhibit A, Appellees’ App. Tab 2A), and the Second Nunc Pro Tunc Judgment (SCR2 at 100-101, Appellant’s App. Tab 3).

5 *13 owed taxes, penalties and interest to HISD, but HISD was not listed as a Plaintiff on the first page of the Final Judgment. (SCR2 at 91, Appellant’s App. Tab 2) 6 As a result, the Trial Court issued its First Nunc Pro Tunc Judgment which identified all of the Harris County Appellees, including HISD and HCCS, on the first page. (SCR2 at 82, Appellant’s App. Tab 2).

Subsequent thereto, the Midtown Appellees filed a Motion for Second Judgment Nunc Pro Tunc because, although: (i) HCCS was identified as a Plaintiff Taxing Unit, (ii) the Final Judgment awarded HCCS relief, and (iii) the Delinquent Tax Records prove that Appellant owed taxes, penalties and interest to HCCS, HCCS was not listed in the Recovery Chart. 7 (SCR2 at 94-97). As a result, the Trial Court found that the Final Judgment and the First Nunc Pro Tunc Judgment did not match the Judgment rendered, and issued the Second Nunc Pro Tunc Judgment (SCR2 at 107; and 98-106, Appellant’s App. Tab 3).

Then, on November 17, 2014, Appellant filed his Notice of Appeal. (CR at 117-19). 6 See also Greater Southeast Management District’s Motion for Judgment Nunc Pro Tunc. (HISD “is not included on the first page of the judgment with the other tax units … [but] Houston ISD is included in the table showing the amounts recovered.” (SCR2 at 67-68, ¶ I). 7

“Recovery Chart” refers to the charts on pages 3-4 of the Final Judgment, the First Nunc Pro Tunc Judgment, and the Second Nunc Pro Tunc Judgment, which identify - for each Tract - the taxing jurisdictions that are owed taxes, penalties and interest, and the amounts they are owed. (SCR2 at 27-28, 84-85 and 100-101, Appellant’s App. Tabs 1, 2 and 3, respectively).

SUMMARY OF THE ARGUMENT

*14 The First and Second Nunc Pro Tunc Judgments were properly issued because the Trial Court had the inherent power to do so, and because the Trial Court factually determined that the Judgements entered did not correspond to the Judgment rendered because: (i) even though HISD was included in the Final Judgment (i.e., the Judgment showed that taxes were due to HISD), HISD’s name was not typed-out on page 1, and (ii) even though the Judgment awarded the amounts listed on the Delinquent Tax Records, the specific amounts were not listed in the Recovery Chart.

Moreover, Appellant’s Issues Nos. 1 through 3 have no merit. Appellant’s Issue No. 1 has no merit because a Trial Judge is free to consider written documents, previous judgments and/or his personal recollection when granting a judgment nunc pro tunc, and the First and Second Nunc Pro Tunc Judgments are based on sufficient evidence.

Appellant’s Issue No. 2 has no merit because it is based on a false premise, i.e. that HISD was not awarded a Judgment against Appellant in the Final Judgment. To the contrary, the Plaintiff Taxing Units, which included the Intervenors, were granted a judgment against Appellant, and Houston ISD is specifically awarded taxes, penalties and interest in the Recovery Chart.

For the same reasons, Appellants’ Issue No. 3 has no merit as to HISD. Furthermore, because; (i) the Intervention sought to recover a monetary judgment 7 *15 for the Harris County Appellees, including HISD and HCCS and others, (ii) the Intervention was supported by Delinquent Tax Records that prove Appellant owes taxes, penalties and interest to HISD and HCCS (iii) the Delinquent Tax Records were admitted into evidence at trial, and (iv) HCCS was always listed as a Plaintiff Taxing Unit, Appellant’s Issue No. 3 has no merit as to HCCS.

Finally, Appellant failed to prove that any reversible error occurred, or that the Trial Court abused its discretion. Therefore, the Trial Court’s Final Judgement, First Nunc Pro Tunc Judgment and Second Nunc Pro Tunc Judgment should be affirmed in their entirety. 8 *16 ARGUMENT AND AUTHORITIES I. THE FIRST AND SECOND NUNC PRO TUNC JUDGMENTS WERE

PROPERLY ISSUED.

The First and Second Nunc Pro Tunc Judgments were properly issued because

the Trial Court had the inherent power to do so, and because the Trial Court factually determined that the Judgements entered did not correspond to the Judgment rendered because: (i) even though HISD was included in the Final Judgment, (e.g. the Judgment showed that taxes were due to HISD), HISD’s name was not typed-out on page 1, and (ii) even though HCCS was named on page 1, the evidence proved HCCS was owed money, and the Judgment awarded the amounts listed in the Delinquent Tax Records, HCCS was not included in the Recovery Chart. As a result, the Trial Court properly issued nunc pro tunc judgments to correct these clerical errors.

A. T HE P URPOSE OF A J UDGMENT N UNC P RO T UNC “The purpose of a judgment nunc pro tunc is to correct a clerical error in a

judgment after the court’s plenary power has expired. Hernandez v. Lopez , 288 S.W.3d 180, 189-90 (Tex.App-Houston [1 st Dist.] 2009, no pet); LaGoye v. Victoria Wood Condominium Ass’n , 112 S.W.3d 777, 783 (Tex.App.-Houston [14 th Dist.] 2003, no pet.), citing Escobar v. Escobar , 711 S.W.2d 230, 231 (Tex. 1986). A clerical error is a “mistake or omission” in the judgment entered compared to the judgment rendered. Id ., citing Andrews v. Koch , 702 S.W.2d 584, 585 (Tex. 1986);

9 *17 Universal Underwriters Ins. Co. v. Ferguson , 471 S.W.2d 28, 29-30 (Tex. 1971). It occurs if there is a mistake when the judgment is reduced to writing. Burgess v. Burgess , 834 S.W.2d 538, 540 (Tex.App.-Houston [1 st Dist.] 1992, no pet.) (“A clerical error is a mistake occurring in the reduction of the judgment to writing…”).

B. T HE T RIAL C OURT ’ S I NHERENT P OWER A trial court has the inherent power to issue nunc pro tunc judgments.

Coleman v. Zapp , 151 S.W. 1040, 1041 (Tex. 1912): Hence it is that from the earliest times the power of correcting or amending their records, by nunc pro tunc entry, so as to faithfully recite their action, has been possessed and exercised by the courts as an inherent right, independent of any statute, and in the absences of express provision, unaffected by limitation.

See also, Shelby v. Shelby , 517 S.W.2d 696, 697-98 (Tex.App.-Houston [1 st Dist.] 1974, writ ref’d n.r.e.). Furthermore, a trial court’s use of that power will not be disturbed absent a clear abuse of discretion. Ferguson v. Naylor , 860 S.W.2d 123 127 (Tex.App.-Amarillo 1993, writ denied).

C. T HE T RIAL C OURT D ETERMINES WHAT J UDGMENT WAS R ENDERED “The question of what judgment the trial court actually rendered is initially a

question of fact for the trial court.” Randle v. Randle , No. 01-96-00459-CV, 1997 WL 7026, at *2 (Tex.App.-Houston [1 st Dist.] 1997, no pet.) (op. per curiam), citing

10 *18 Escobar , 711 S.W.2d at 232; America’s Favorite Chicken Co. v. Galvan , 897 S.W.2d 874, 877 (Tex.App.-San Antonio 1995, writ denied); Thompson v. Tex. Dept. of Human Resources , 859 S.W.2d 482, 484 (Tex.App.-San Antonio 1993, no writ). Thereafter, an appellate court may only review the trial court’s factual determination for no evidence and factual insufficiency of the evidence, and cannot substitute its judgment for the judgment of the trial court. Randle , 1997 WL 7026, at *2, Escobar , 711 S.W.2d at 232; Thompson , 859 S.W.2d at 484-85.

D. T HE T RIAL C OURT D ETERMINED THAT THE J UDGEMENTS ENTERED DID NOT CORRESPOND TO THE J UDGMENTS RENDERED For both the First and Second Nunc Pro Tunc Judgments, the Trial Court determined that the Judgment entered did not correspond to the Judgment rendered. (i) THE FIRST NUNC PRO TUNC JUDGMENT For the First Nunc Pro Tunc Judgment, the Trial Court found: that the Judgment entered does not correspond to the Judgment as rendered because of the follow errors Plaintiff lef. (sic) off the first page. Specifically HOUSTON INDEPENDENT SCHOOL DISTRICT show tax amounts due in the judgment, but is not listed as a Plaintiff in the suit

(SCR2 at 91, Appellant’s App. Tab 2). Obvious typographical errors are clerical errors. Hernandez , 288 S.W.3d at 190, citing Ex parte Hogan , 916 S.W.2d 82, 85 (Tex.App.-Houston [1 st Dist.] 1996, orig. proceeding). Moreover, a judgment non

11 *19 pro tunc is proper to add the name of a defendant omitted from the original judgment, or to correct a party’s name. Batson v. Bentley , 4 S.W.2d 577, 578 (Tex.Civ.App.- Amarillo 1928, no pet.) (Contract and pleadings authorized trial court to enter judgment nunc pro tunc adding the name of an omitted defendant); Carlyle Real Estate Ltd. P’ship-X v. Leibman , 782 S.W.2d 230, 233 (Tex.App.-Houston [1 st Dist.] 1989, no writ) (“We hold that the trial court did not err in rendering the judgment nunc pro tunc to accurately reflect the legal name of the party against whom the judgment was rendered.”).

Here, however: (i) HISD was already incorporated 8 , by reference as a Plaintiff Taxing Unit on page 1 of the Final Judgment, and (ii) Houston ISD was already listed in the Final Judgment’s Recovery Chart. (SCR2 at 25 and 27-28, Appellant’s App. Tab 1). Therefore, HISD was not being added to the Final Judgment, but instead, the change was that:

“HOUSTON INDEPENDENT SCHOOL DISTRICT (HOUSTON ISD)”

was typed-out on page 1 of the First Nunc Pro Tunc Judgment. (SCR2 at 82, Appellant’s App. Tab 2). Clearly this is the correction of an obvious typographical error, and thus properly changed via a nunc pro tunc judgment. 8

Page 1 of the Final Judgment incorporates the Intervenors into the definition of “Plaintiff Taxing Units(s)”, and HISD is a named Intervenor in the Original Intervention. (SCR2 at 25, Appellant’s App. Tax 1) and (SCR2 at 3. Appellees’ App. Tab 1).

12 *20 (ii) THE SECOND NUNC PRO TUNC JUDGMENT For the Second Nunc Pro Tunc Judgment, the Trial Court found: that the Judgment entered does not correspond to the Judgment as rendered because of the following errors HOUSTON COMMUNITY COLLEGE SYSTEM is not included in the figure blocks for Tract 1 through Tract 5 even though the Delinquent Tax statements show the amounts owed

(SCR2 at 107, Appellant’s App. Tab 3). This finding is specifically based upon his recollection that: (i) “the Delinquent Tax statements show the amounts owed” to HCCS, and (ii) those amounts were included in the Judgement he rendered. ( Id .).

Evidence that a clerical error was made may come from a number of sources, including written documents and the trial judge’s personal recollection. Claxton v. (Upper) Lake Fork Water Control and Imp. Dist. No. 1 , 220 S.W.3d 537, 545 (Tex.App.-Texarkana 2006, pet. denied), citing Riner v. Briargrove Park Prop. Owners, Inc. , 976 S.W.2d 680, 683 (Tex.App.-Houston [1 st Dist.] 1997, no writ). Furthermore, the trial judge’s recollection, and/or recitations alone, may provide sufficient evidence that a clerical error occurred and that the nunc pro tunc judgment correctly reflects the judgment rendered. Claxton , 220 S.W.3d at 545, citing Pruet v. Coastal States Trading, Inc. , 715 S.W.2d 702, 704 (Tex.App.-Houston [1 st Dist.] 1986, no writ); Barton v. Gillespie , 178 S.W.3d 121, 127 (Tex.App.-Houston [1 st Dist.] 2005, no pet.) (“Because the trial court relied on its personal recollection, we

13 *21 will presume the trial court’s recollection supports the finding that the error was clerical …”).

In this case, the Delinquent Tax Records are prima facie proof 9 that Appellant owed HCCS taxes, penalties and interest on Tracts 1 through 5 10 . Moreover, the Trial Court clearly rendered his Judgment based on the Delinquent Tax Records:

Ms. Hernandez On behalf of the Intervenors, I’m offering into evidence 1, 2, 3 – 5 certified tax statements marked as Harris County Exhibit A and one document marked as Harris County Exhibit B. We seek to recoup all past due taxes, penalties, interest, and delinquent city liens. * * *

The Court: They are admitted. * * * Judgment for Plaintiffs. 11 The Court: (RR Vol. 1, p. 5, l. 13-24, RR Vol. 2, Harris County Exhibits A and B, Appellees’ App. Tabs 2 and 2A). However, although the amounts owed to all other Harris 9

The Tax Code provides that Delinquent Tax Records constitute prima facie evidence “that the amount of tax alleged to be delinquent against the property and the amount of penalties and interest due on that tax as listed are the correct amounts.” Section. 33.47(a), T EX . P ROP . T AX . C ODE . Further, the Texas Supreme Court has held that Delinquent Tax Records, by themselves, are prima facie evidence of every fact necessary for a taxing jurisdiction to prevail. Davis v. City of Austin , 632 S.W.2d 331, 333 (Tex. 1982) (“Under these principles, the taxing authority established its prima facie case as to every material fact necessary to establish the cause of action when it introduced a copy of the delinquent tax record, certified by the proper taxing authority to be true and correct with the amount stated thereon to be unpaid.”). 10 (RR Vol. 2, Harris County Exhibit A: Tract 1 – 0008 Acct., p. 1-2 of 3; Tract 2 – 0006 Acct, p. 1-3 of 4, Tract 3 – 0003 Acct, p. 1-2 of 3, Tract 4 – 0010 Acct, p. 1-3 of 4 and Tract 5 – 0009 Acct, p. 1-3 of 4). 11

Based upon the definition of Plaintiff Taxing Units, “Plaintiffs” impliedly include the Intervenors HISD and HCCS. Zamora v. Salinas , 422 S.W.2d 249, 251 (Tex.App.-Corpus Christi 1967, writ ref’d n.r.e.) Findings “which may properly be implied in support of it are legally and factually sufficient” to justify the nunc pro tunc judgment.

14 *22 County Appellees were transcribed from the Delinquent Tax Records to the Final Judgment, the amounts owed to HCCS were not transcribed.

Therefore, because: (i) the Judgment rendered included an award of the amounts reflected in the Delinquent Tax Records, (ii) the Delinquent Tax Records prove that Appellant owes taxes, penalties and interest to HCCS 12 , and (iii) the Judgment entered did not contain those amounts due to a transcription error, the error is a clerical error which may be corrected via a nunc pro tunc judgment. 13 Burgess 834 S.W.2d at 540. (“In this case, the error arose from the writing failing to properly reflect the judgment as rendered, meaning it was a clerical error.”).

II. APPELLANT’S ISSUES HAVE NO MERIT

As demonstrated in Section I above, the Trial Court properly issued its First and Second Nunc Pro Tunc Judgments. Nevertheless, Appellant seeks to have one or both of the nunc pro tunc judgments reversed. However, Appellant’s Issues have no merit, and therefore all of the Trial Court’s judgments should be affirmed. 12

As a result, and pursuant to § 33.47, T EX . P ROP . T AX C ODE , no judicial reasoning or determination is required to calculate the amount of taxes, penalties and interest that is owed. 13

Transcription errors involving monetary amounts are clerical errors which can be corrected via a nunc pro tunc judgment. SLT Dealer Group, Ltd. v. AmeriCredit Fin. Services, Inc. , 336 S.W.3d 822, 832-33 (Tex.App.-Houston [1 st Dist.] 2011, no pet.), citing Fiske v. Fiske , No. 01- 03-00048-CV, 2004 WL 1847368, at *5 (Tex.App.-Houston [1 st Dist.] Aug. 19, 2004, no pet.) (mem.op.); Scott v. Scott , 408 S.W.2d 135, 137 (Tex.App.-Fort Worth 1966, writ dism’d); Wedgeworth v. Pope , 12 S.W.2d 1045, 1047 (Tex.Civ.App.-Fort Worth 1928, writ ref’d).

15 *23 A. APPELLANT’S ISSUE NO. 1 HAS NO MERIT BECAUSE THE FIRST AND SECOND NUNC PRO TUNC JUDGMENTS ARE BASED ON SUFFICENT EVIDENCE.

Appellant’s Issue No. 1 asserts that the Delinquent Tax Records cannot be used to support the First and Second Nunc Pro Tunc Judgments because they were not attached to, or referenced in, the Final Judgment:

[T]he trial exhibits that Appellees attached to the form of judgment presented to, and signed by, the trial court … cannot be used, as argued by Appellees, to create a ‘clerical’ error that would permit the trial court to enter nunc pro tunc judgments.”

(Brief at 13-14). However, evidence supporting a nunc pro tunc judgment “may come from a number of sources, including oral testimony, written documents, previous judgments, docket entries, or the trial judge’s personal recollection.” Claxton , 220 S.W.3d at 545, citing Riner, 976 S.W.2d at 683.

Here, for the First Nunc Pro Tunc Judgment, the Trial Judge found that the Judgment entered did not match the Judgment he rendered, because HISD was left off the first page, but the Final Judgment “show[s] tax amounts due” to HISD. (SCR2 at 91, Appellant’s App. Tab 2). Accordingly, his finding is based upon a written document/previous judgment (i.e., the “Final Judgment”), and his personal recollection of what the Final Judgment shows, and what judgment he rendered.

Moreover, for the Second Nunc Pro Tunc Judgment, the Trial Judge specifically found that the Judgment entered did not match the Judgment he rendered because: (i) HCCS was not listed in the Recovery Chart, (ii) even though the

16 *24 Delinquent Tax Records, which Appellant’s admits was attached to the proposed judgment 14 , “show the amounts owed.” (Brief at 13-14; SCR2 at 107, Appellant’s App. Tab 3). Accordingly, his finding is based upon written documents (i.e., the Delinquent Tax Records and the proposed judgment), and his personal recollection of what the Delinquent Tax Records show, and what judgment he rendered.

A “trial judge’s recollection of facts has the dignity and force of evidence.” Claxton , 220 S.W.3d at 545, citing Ft. Worth & D.C. Ry. Co. v. Roberts , 81 S.W. 25, 26 (Tex. 1904) and Wood v. Paulus , 524 S.W.2d 749, 755 (Tex.Civ.App.-Corpus Christi 1975, writ ref’d n.r.e.). Further, if the Trial Judge relies on his personal recollection, “a presumption arises that his personal recollections supports the finding of clerical error.” Claxton , 220 S.W.3d at 545, citing Pruet , 715 S.W.2d at 704; Barton , 178 S.W.3d at 127.

Accordingly, Appellant’s Issue No. 1 has no merit because the First and Second Nunc Pro Tunc Judgments were supported by sufficient evidence; and therefore this Court should affirm the Final Judgment, the First Nunc Pro Tunc Judgment, and the Second Nunc Pro Tunc Judgment. 14

Even the inadvertent failure to attach an exhibit to a judgement is a clerical error that can be cured by a nunc pro tunc judgment. Operation Rescue-National v. Planned Parenthood of Houston and Southeast Texas, Inc. , 937 S.W.2d 60, 86 (Tex.App.-Houston [14 th Dist.] 1996, aff’d as modified on other grounds , 975 S.W.2d 546 (Tex. 1998)) (“Failure to attach the exhibits to the judgment is a clerical error, not a judicial error. Therefore, the trial court could properly enter a judgment nunc pro tunc after expiration of its plenary power.”).

17 *25 B. APPELLANT’S ISSUE NO. 2 HAS NO MERIT BECAUSE IT IS BASED ON A FALSE PREMISE, I.E., THAT THE FINAL JUDGMENT DID NOT AWARD HISD A JUDGMENT AGAINST APPELLANT.

Appellant’s Issue No. 2 is based on the false premise that the Final Judgment did not award HISD a judgment against Appellant. (Brief at 4, Issue No. 2) (“In this revised final order, HISD was awarded judgment against Mr. Cohen, which had been denied in the first final order.”). But the Final Judgment awarded a judgment against Mr. Cohen and in favor of the Plaintiff Taxing Units. (SCR2 at 25-26, Appellant’s App. Tab 1) (“IT IS ORDERED that the Plaintiff Taxing Unit(s) recover of and from the Defendant(s) 15 , as indicated above, the total sum or money set out below…”). Moreover, Plaintiff Taxing Units was defined to include the Intervenors, and HISD was listed as an Intervenor in the Intervention. (SCR2 at 25, Appellant’s App. Tab 1; SCR2 at 3-15, Appellees’ App. Tab 1). Furthermore, Houston ISD was included in the Final Judgment’s Recovery Chart setting forth which taxing units would recover from Appellant, and the amount each would recover. (SCR2 at 27-28, Appellant’s App. Tab 1). In addition, the Trial Judge’s decision to grant the First Nunc Pro Tunc Judgment was based on his finding that the Final Judgment shows that tax amounts were due to HISD. (SCR2 at 91, Appellant’s App. Tab 2). Accordingly, Appellant’s Issue No. 2 has no merit because it is based on a false 15

Appellant was the only identified Defendant. (SCR2 at 25, Appellant’s App. Tab 1). 18 *26 premise; and therefore this Court should affirm the Final Judgment, the First Nunc Pro Tunc Judgment, and the Second Nunc Pro Tunc Judgment.

C. APPELLANT’S ISSUE NO. 3 HAS NO MERIT FOR THE SAME REASON, AND BECAUSE HCCS WAS A NAMED PLAINTIFF TAXING UNIT WHO WAS AWARDED A JDUGMENT AGAINST APPELLANT.

Appellant’s Issue No. 3 begins by re-asserting the same false premise that HISD was not awarded a judgment against Appellant in the Final Judgment. As a result, the Harris County Appellees herby and herein incorporate its response to Appellant’s Issue No. 2.

Appellant then falsely asserts that HCCS was not included in the Final Judgment or the First Nunc Pro Tunc Judgment. To the contrary, HCCS was listed as a Plaintiff Taxing Unit on both. (SCR2 at 25 and 82, Appellant’s App. Tabs 2 and 3). Additionally, HCCS was a named Intervenor. (SCR2 at 3, Appellees’ App. Tab 1). Furthermore, both the Delinquent Tax Records attached to the Intervention, and the Delinquent Tax Records introduced at trial, identified HCCS as a Taxing Unit (Code #48), and specified the amounts of taxes, penalties and interest that Appellant owed HCCS. (SCR2 at 7-15, Appellees’ App. Tab 1A; RR Vol. 1, p. 5, l. 13-23, Appellees’ App. Tab 2; and RR Vol. 2, Harris County Exhibits A and B, Appellees’ App. Tab 2A). Therefore the Trial Court granted the Second Nunc Pro Tunc Judgment because HCCS was “not included on the figure blocks for Tract 1 through

19 *27 5 even though the Delinquent Tax statements show the amounts owed…” (CR at 107, Appellant’s App. Tab 3).

As a result, the Trial Court did not err when it granted the Second Nunc Pro Tunc Judgment based upon the language in the First Nunc Pro Tunc Judgment (i.e. the Recovery Chart) and the Delinquent Tax Records. Sederholm v. Neville , No. 01- 12-00215-CV, 2014 WL 2625633, at *3 (Tex.App.-Houston [1 st Dist.] Jun 12, 2014, no pet.) (mem. op.) (A Trial Court’s decision to grant a Judgment Nunc Pro Tunc can be based on evidence “from oral testimony of witnesses, written documents, previous judgments, docket entries, or the trial judge’s personal recollection.”), citing Hernandez , 288 S.W.3d at 185. Accordingly, Appellant’s Issue No. 3 has no merit because it is based on false premises, and because HCCS was a named Plaintiff Taxing Unit who was awarded a judgment against Appellant. Therefore this Court should affirm the Final Judgment, the First Nunc Pro Tunc Judgment, and the Second Nunc Pro Tunc Judgment. III. APPELLANT FAILED TO PROVE ANY REVERSIBLE ERROR

OCCURRED, OR THAT THE TRIAL COURT ABUSED ITS DISCRETION. Pursuant to Rule 44.1, T EX . R. A PP . P., no judgment may be reversed on appeal

unless “the error complained of: (1) probably caused the rendition of an improper judgment; or (2) probably prevented the appellant from properly presenting the case

20 *28 to the court of appeals.” First, Appellant does not contend that any alleged error prevented him from properly presenting his case to this Court. Second, although Appellant does assert that the Trial Court erred in issuing the Final Judgment, First Nunc Pro Tunc Judgment and Second Nunc Pro Tunc Judgment, the Appellant failed to prove there was any error because the Appellees presented prima facie cases at trial, and the First and Second Nunc Pro Tunc Judgments were properly issued.

Furthermore, Appellant failed to show that the Trial Court abused its discretion. The test for an abuse of discretion is whether the trial court acted without reference to any guiding rules or principles, or arbitrarily or unreasonably. Perry Homes v. Cull , 258 S.W.3d 580, 602 (Tex. 2008), citing, Cire v. Cummings , 134 S.W.3d 835, 838-39 (Tex.2004). However, “[a] trial court does not abuse its discretion if it bases it decision on conflicting evidence and some evidence supports its decision.” In re Barber , 982 S.W.2d 364, 366 (Tex. LaG1998), Unifund CCR Partners v. Villa , 299 S.W.3d 92, 97 (Tex.2009). In this case, the Trial Court acted in accordance with guiding rules and principles (i.e. Section 33.47, T EX . P ROP . T AX C ODE ); and there is at least some evidence to support the Trial Court’s Final Judgment, First Nunc Pro Tunc Judgment and Second Nunc Pro Tunc Judgment (the Delinquent Tax Records, the previous judgments and his personal recollection).

CONCLUSION AND PRAYER FOR RELIEF

*29 The Trial Court did not err when it issued its Final Judgment, its First Nunc Pro Tunc Judgment, or its Second Nunc Pro Tunc Judgment. Moreover, Appellant’s Issues are entirely without merit, and Appellant has failed to prove that any reversible error occurred, or that the Trial Court abused its discretion. Therefore, the Trial Court's Final Judgment, and First and Second Nunc Pro Tunc Judgments, should be affirmed in their entirety.

Respectfully submitted,

LINEBARGER GOGGAN

BLAIR & SAMPSON, LLP Edward J. (Nick) Nicholas State Bar No. 14991350 4828 Loop Central Drive, Suite 600 Houston, Texas 77081 (713) 844-3405 direct phone (713) 844-3400 main phone (713) 8454-3504 fax

ATTORNEYS FOR APPELLANT

CERTIFICATE OF COMPLIANCE

*30 I certify that this document was produced on a computer using Microsoft Word 2013 and contains 4,549 words, as determined by the computer software’s word-count function, excluding the sections of the document listed in Rule 9.4(i)(1), T EX . R. A PP . P.

Edward J. (Nick) Nicholas

CERTIFICATE OF SERVICE

I certify that a copy of the Brief of Appellant was served on the following counsel of record via electronic mail to Mr. George F. May at george@twomeymay.com, and to Mr. Greg East at geast@pbfcm.com.

Edward J. (Nick) Nicholas 23

CASE NO. 01-14-00914-CV

*31 IN THE COURT OF APPEALS FOR THE FIRST JUDICIAL DISTRICT OF TEXAS HOUSTON, TEXAS

JAY COHEN,

APPELLANT v.

MIDTOWN MANAGEMENT DISTRICT, ET AL,

APPELLEES On Appeal from the 133 rd Judicial District Court of Harris County, Texas, Trial Court Case No. 2013-16814

APPELLEES’ APPENDIX

LIST OF DOCUMENTS

1. Harris County’s Original Intervention (SCR2 at 3-6) Tab 1 2. Original Intervention Exhibit A – Harris County Appellees’ Tab 1A

Certified Tax Records (SCR2 at 7-15) Transcript of November 15, 2013 Final Trial – (RR Vol. 1, p.

3. Tab 2 1-7) Trial Exhibit A – Harris County Appellees’ Certified Tax

4. Tab 2A Records (RR Vol. 2) *32 Exhibit 1

3

*33 *34 4 *35 5 *36 6

*37 Exhibit 1A

7

*38 *39 8 *40 9

*41 10 *42 11 *43 12 *44 13 *45 14 *46 15

FILED IN

*47 1st COURT OF APPEALS HOUSTON, TEXAS 7/9/2015 1:07:02 PM CHRISTOPHER A. PRINE Clerk

Exhibit 2

FINAL TRIAL

*48 1 REPORTER'S RECORD VOLUME 1 OF 2 VOLUMES TRIAL COURT CAUSE NO. 2013-16814 APPELLATE CAUSE NO. 01-14-00914-CV MIDTOWN MANAGEMENT DISTRICT( IN THE DISTRICT COURT OF AND GREATER SOUTHWEST ( MANAGEMENT DISTRICT ( Plaintiffs ( and HARRIS COUNTY, THE HARRIS COUNTY DEPARTMENT OF ( EDUCATION, THE PORT OF ( HOUSTON AUTHORITY OF HARRIS( COUNTY, THE HARRIS COUNTY ( HARRIS COUNTY, TEXAS FLOOD CONTROL DISTRICT, THE( HARRIS COUNTY HOSPITAL ( DISTRICT, THE CITY OF ( HOUSTON, HOUSTON INDEPENDENT SCHOOL DISTRICT, AND HOUSTON COMMUNITY COLLEGE SYSTEM ( Intervenors ( v. (

JAY COHEN (

Defendant ( 133rd JUDICIAL DISTRICT _______________________________________________________

FINAL TRIAL

_______________________________________________________ On the 15th day of November, 2013, the following proceedings came on to be held in the above-titled and numbered cause before the Honorable JACLANEL McFARLAND, Judge Presiding, held in Houston, Harris County, Texas.

Proceedings reported by computerized stenotype machine. DARLENE STEIN

OFFICIAL COURT REPORTER 133RD DISTRICT COURT

HARRIS COUNTY, TEXAS

DARLENE STEIN

FINAL TRIAL

*49 2

APPEARANCES

Ms. Yolanda M. Humphrey

SBN 24009764

1235 North Loop West, Suite 600 Houston, Texas 77008 Telephone: (713) 862-1429 (Fax) Attorney for Plaintiffs Ms. Angelica M. Hernandez

SBN 00797872

Linebarger, Goggan, Blair & Sampson, L.L.P. 1300 Main Street, Suite 300 Houston, Texas 77002 Telephone: (713) 844-3501 Attorney for Intervenors

DARLENE STEIN

FINAL TRIAL

*50 3 EXHIBITS OFFERED BY THE PLAINTIFF EXHIBIT DESCRIPTION OFFERED ADMITTED VOL. A. Tax Statements 5 5 1 B. Tax Statements 5 5 1 EXHIBITS OFFERED BY THE INTERVENORS EXHIBIT DESCRIPTION OFFERED ADMITTED VOL. A. Tax Statements 5 5 1 B. Affidavit 5 5 1

DARLENE STEIN

FINAL TRIAL

*51 4

(P R O C E E D I N G S)

THE COURT: The court calls cause number

2013-16814, Greater Southwest Management District vs. Jay H. Cohen.

If you will announce who you are and who you represent. MS. HUMPHREY: Yolanda Humphrey and I'm here on behalf of Plaintiffs. MS. HERNANDEZ: Angelica Hernandez on behalf of the Intervenors, Harris County and County Wide Jurisdiction, City of Houston, Houston Community College System and Houston Independent School District.

THE COURT: I call Mr. Cohen. Are you in the courtroom? Deputy, have you gone out and called his name in the hall? Any answer? BAILIFF: No answer, Judge. THE COURT: Okay. Let the record reflect

that Jay H. Cohen has previously filed an answer in this cause and has been given notice of the trial date and he does not appear to be in the courtroom or in the courthouse since the bailiff has gone out and called his name outside of the courtroom and in the courthouse. So he has failed to appear in court.

DARLENE STEIN

FINAL TRIAL

*52 5 You may proceed, counsel. MS. HUMPHREY: My name is Yolanda

Humphrey. I have certified delinquent tax statements that have been marked Exhibit A and Exhibit B that I would like to offer into evidence on behalf of the Plaintiffs.

THE COURT: Any objection? MS. HERNANDEZ: No objection, Judge. THE COURT: They are admitted. (Exhibits A and B were marked and admitted

in evidence.) MS. HUMPHREY: Thank you, Your Honor. MS. HERNANDEZ: On behalf of the

Intervenors, I'm offering into evidence 1, 2, 3 -- 5 certified tax statements marked as Harris County Exhibit A and one document marked as Harris County Exhibit B. We seek to recoup all past due taxes, penalties, interest, and delinquent city liens.

THE COURT: Any objection? MS. HUMPHREY: No objection, Your Honor. THE COURT: They are admitted. (Harris County Exhibits A and B were

offered and admitted into evidence.) THE COURT: Judgment for Plaintiffs. MS. HUMPHREY: May I be excused?

DARLENE STEIN

*53 Final Trial 6 THE COURT: You're excused. Have a good weekend. (Proceedings concluded.)

DARLENE STEIN

*54 Final Trial 7 STATE OF TEXAS COUNTY OF HARRIS

I, DARLENE STEIN, Official Court Reporter in and for the 133rd District Court of Harris, State of Texas, do hereby certify that the above and foregoing contains a true and correct transcription of all portions of evidence and other proceedings requested in writing by counsel for the parties to be included in this volume of the Reporter's Record in the above-styled and numbered cause, all of which occurred in open court or in chambers and were reported by me.

I further certify that this Reporter's Record of the proceedings truly and correctly reflects the exhibits, if any, offered by the respective parties.

I further certify that the total cost for the preparation of this Reporter's Record is $131.00 and was paid by Mr. George F. May. /s/Darlene Stein_________

DARLENE STEIN, CSR

Texas CSR 2557 Official Court Reporter 133rd District Court Harris County, Texas 201 Caroline, 11th Floor Houston, Texas 77002 Telephone: (713) 368-6402 Expiration: 12/31/2016

DARLENE STEIN

*55 Exhibit 2A

CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

*56 3 3 Q35 '30 Q35 '30 Q Q A19 A19 *149 *149 11- 11- *1 u‘ *1 u‘ MIKE SULLIVAN MIKE SULLIVAN HARRIS COUNTY TAX ASSESSOR-COLLECTOR HARRIS COUNTY TAX ASSESSOR-COLLECTOR 1001 PRESTON AVE SUITE 100 1001 PRESTON AVE SUITE 100 HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002 H I B ﬁ H I B ﬁ Certiﬁed Owner Certiﬁed Owner Legal Description: Legal Description: COHEN JAYH COHEN JAYH LT8&TRS 98 11r>& 12 BLK428 LT8&TRS 98 11r>& 12 BLK428

1715 W ALABAMA ST OFC 3 1715 W ALABAMA ST OFC 3

SSBB SSBB

HOUSTON TX 77098-2807 HOUSTON TX 77098-2807

Legal Acres: Legal Acres: .2511 .2511 51 Year 51 Year Acc()|1ntN() Acc()|1ntN() Parcel Address: 2113 BASTROP ST Parcel Address: 2113 BASTROP ST As of Date As of Date 11/01/2013 11/01/2013 APPR. DIST#: 0021460000008 APPR. DIST#: 0021460000008 Print Date: Print Date: 11/01/2013 11/01/2013 Printed By LBCSOMOZA Printed By LBCSOMOZA Cause N0 Cause N0 2013-16814 Suit 2010-06881 Jud 2013-16814 Suit 2010-06881 Jud 2013 Value; 2013 Value; $79 454 $79 454

Base Base Tax Tax Penalties & Penalties & Collection Collection Total Total

E: >< E: >< Due Due Value Value itsl itsl Interest Interest Fees Fees

$1,488.85 I $1,488.85 I

1 1 $729.83 $729.83 $759.02 $759.02 $0.00 $0.00 I\J S S I\J S S $501.05 $501.05 $245.61 $245.61 $255.44 $255.44 $0.00 $0.00

$39.70 I $39.70 I

$19.46 $19.46 $20.24 $20.24 $0.00 $0.00 $22.82 $22.82 $11.19 $11.19 $1 1.63 $1 1.63 $0.00 $0.00 $247.36 $247.36 $121.25 $121.25 $126.1 1 $126.1 1 $0.00 $0.00 $7.52 ‘ $7.52 ‘ $3.69 $3.69 $3.83 $3.83 $0.00 $0.00 $60.66 ' $60.66 ' $118.99 $118.99 $58.33 $58.33 $0.00 $0.00 A___i A___i $822.16 $822.16 $403.02 $403.02 $419.14 $419.14 $0.00 $0.00 <J\J>-l>~J>-l>-|>4> <J\J>-l>~J>-l>-|>4> --oo4>wt\>>—-O --oo4>wt\>>—-O $3,248.45 $3,248.45 - 1 ¥._._ . - 1 ¥._._ . $1,592.38 $1,592.38 $1,656.07 $1,656.07 $0.00 $0.00 “$187.74 “$187.74 I I $99.02 $99.02 $88.72 $88.72 $0.00 $0.00 $33.57l $33.57l $30.08 ' $30.08 ' $63.65 $63.65 $0.00 $0.00 $4.74 $4.74 $2.50 $2.50 $2.24 $2.24 $0.00 $0.00 $2.65 $2.65 $1.25 $1.25 $0.00 $0.00 -J>-J>-D- -J>-J>-D- I\>>—~© I\>>—~© $1.40 $1.40 $31.19 $31.19 43 43 $0.00 $0.00 $16.45 $16.45 $14.74 ' $14.74 ' $0.97 $0.97 $0.51I $0.51I $0.00 I $0.00 I 44 44 $0.46 $0.46 $14.98 $14.98 $7.90 $7.90 $0.00 I $0.00 I $7.08 $7.08

$0.00 I $0.00 I

05-» --oe 05-» --oe $54.68 $54.68 $48.99 $48.99 $103.67 $103.67 $0.00 $0.00 Subtotals for 2009: Subtotals for 2009: $216.03 $216.03 $409.59 $409.59 $193.56 $193.56 $149.44 I $149.44 I $0.00 $0.00 $395.23 $395.23 201 201 $6 000 $6 000 1 1 $245.79 $245.79 $50.54 I $50.54 I $0.00I $0.00I $133.66 $133.66 $83.12 $83.12

$3.63 I $3.63 I

$0.00 I $0.00 I $9.60 I $9.60 I $5.97 $5.97 $3.951 $3.951 $2.40 I $2.40 I $0.00 $0.00

$6.35 I $6.35 I

l l $24.84 I $24.84 I $0.00 $0.00 $40.84 $40.84 $65.68 $65.68 $0.86 I $0.86 I $0.00 $0.00 $1.40 $1.40 $2.26 $2.26 $12.56 $12.56 $0.00 I $0.00 I $20.66 $20.66 $33.22 $33.22 $82.53 I $82.53 I $0.00 $0.00 o~\-a>4>4>-.|>-:=-|=- o~\-a>4>4>-.|>-:=-|=- --oo-z>t.5|\>—-0 --oo-z>t.5|\>—-0 $135.74 $135.74 $218.27 $218.27 $864.27? $864.27? _ W _ W Subtotals [or 2011: Subtotals [or 2011: ____mS537,47 ____mS537,47 ,__.....~ ,__.....~ $748.24 $748.24

1 1 $511.09 $511.09 $237.15 $237.15 $0.00 I $0.00 I I 40 I 40 $82.05 I $82.05 I $0.00 $0.00 $258.89 $258.89 $176.84 $176.84 41 , 41 , I I $12.41I $12.41I $5.76 I $5.76 I $0.00‘ $0.00‘ $18.17 I $18.17 I 42 42 I I $4.00 $4.00 $0.00 $0.00

$8.62 $8.62 $l2.62I $l2.62I

I I

$80.49 $80.49 $37.35 $37.35 $0.00 $0.00 $117.84 $117.84 . . I I $2.92 $2.92 $1.35 I $1.35 I $0.00 I $0.00 I 7 $4.27 I 7 $4.27 I -J;-JR->02 -J;-JR->02 *57 CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL I I Q35 C90 Q35 C90 A1- A1- 11* 11*

PBX A9 PBX A9 MIKE SULLIVAN MIKE SULLIVAN HARRIS COUNTY TAX ASSESSOR-COLLECTOR HARRIS COUNTY TAX ASSESSOR-COLLECTOR 1001 PRESTON AVE., SUITE 100 1001 PRESTON AVE., SUITE 100 HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002 Certiﬁed Owner: Certiﬁed Owner: Legal Description: Legal Description: COHEN JAYH COHEN JAYH LT8&TRS9B11D&12BL1(428 LT8&TRS9B11D&12BL1(428

1715 W ALABAMA ST OFC 3 1715 W ALABAMA ST OFC 3

SSBB SSBB

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

Legal Acres: Legal Acres: .2511 .2511 Aggount N0; Aggount N0; Parcel Address: 2113 BASTROP ST Parcel Address: 2113 BASTROP ST As of Date: As of Date: 11/01/2013 11/01/2013 APPR.DIST#: 0021460000008 APPR.DIST#: 0021460000008 Print Date: Print Date: I1/01/2013 I1/01/2013 Printed By LBCSOMOZA Printed By LBCSOMOZA Cause No: 2013-16814 Suit 2010-06881 Jud Cause No: 2013-16814 Suit 2010-06881 Jud 2013 Value: 2013 Value: $79,454 $79,454

'T—'T- 'T—'T- '—'TTT ' '—'TTT ' 1 1 T’ T” T’ T” “TI “TI Base Base I I Appraised Appraised Tax ; Tax ; T1“ T1“ . . Penalties & Penalties & Collection Collection ‘-1 o -IE ‘-1 o -IE IYCM‘ IYCM‘ Vﬂlllt Vﬂlllt Units I Units I Due Due Interest Interest Fees Fees T2013 T2013 I 48 I 48 $42.93I $42.93I $19.91 I $19.91 I $0.00I $0.00I $62.84I $62.84I II II I61 I61 $282.23I $282.23I $130.95 I $130.95 I $0.00 $0.00 $413.18 I $413.18 I

si, si, g, g, . . g g W , W , ‘ ‘ 117 117 53 53 $518 52 $518 52 $0 00 $0 00 $1 636.05 I $1 636.05 I TOTAL AMOUNT DUE: TOTAL AMOUNT DUE: $3,463.41 $3,463.41 $2,694.95 $2,694.95 $0.00 $0.00 $6,158.36 $6,158.36 Tax Unit Codes: Tax Unit Codes: 1 Houston I.S.D. 1 Houston I.S.D. 40 Harris County 40 Harris County 41 41 Harris County Flood Control Dist Harris County Flood Control Dist 42 42 Port of Houston Authority Port of Houston Authority 43 Harris County Hospital District 43 Harris County Hospital District 44 Harris County Dept. of Education 44 Harris County Dept. of Education 48 48 Houston Community College System Houston Community College System 61 City of Houston 61 City of Houston

IF YOU ARE 65 YEARS OF AGE OR OLDER OR ARE DISABLED AND THE PROPERTY DESCRIBED IN THIS DOCUMENT IS YOUR RESIDENCE HOMESTEAD 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 DISTRJCT REGARDING ANY ENTITLEMENT YOU MA Y HA VE TO A POSTPONEMENT IN THE PAYMENT OF THESE YOU SHOULD CONTACT THE APPRAISAL DISTRJCT REGARDING ANY ENTITLEMENT YOU MA Y HA VE TO A POSTPONEMENT IN THE PAYMENT OF THESE TAXES. TAXES.

Partial Statement: Other Years and Tax Units may be due Partial Statement: Other Years and Tax Units may be due Totals By Tax Unit I Totals By Tax Unit I _____ _____ ___ _ ___ _ IM, IM, Tax Tax Base Base Penalties Penalties Collection Collection 1 1 Units Units Tax Due Tax Due & Interest & Interest Fees Fees Total Total .. .. __ __ 1 1 L. .. L. .. $1,585.73 $1,585.73 $1 ,234_33 $1 ,234_33 $0.00 $0.00 $2,820.06 $2,820.06 40 40 $539.14 $539.14 $418.1 1 $418.1 1 $0.00 $0.00 $957.25 $957.25 41 41 $40.34 $40.34 $31.87 $31.87 $0.00 $0.00 $72.21 $72.21

I I 42 42 $25.16 $25.16 $19.28 $19.28 $0.00 $0.00 $44.44 $44.44 43 43 1 1 $259.03 $259.03 $203.04 $203.04 $0.00 $0.00 $462.07 $462.07 $8.52 $8.52 I I I- ._ I- ._ 44 44 $6.50 J $6.50 J $0.00 $0.00 $15.02 $15.02 $1,557.28 I $1,557.28 I CW Total H 40 T 44 CW Total H 40 T 44 $872.19 $872.19 $678.80 $678.80 $0.00 $0.00 $1,550.99 $1,550.99 I,_ . I,_ . . .

I I

48 48 $129.82 $129.82 $100.21 $100.21 $0.00 $0.00 $230.03 $230.03 61 61 I I $875.67 $875.67 $681.61 $681.61 $0.00 $0.00

1 1 TOTAL AMOUNT DUE TOTAL AMOUNT DUE $3,463.41 $3,463.41 $2,694.95 $2,694.95 $0.00 $0.00 $6,158.36 $6,158.36 .1.88 .1.88 P P

age age 2 2

CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

*58 <2-‘S coo <2-‘S coo ‘tI14»? ‘tI14»?

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,,{ \$\. \ ,,{ \$\. \ EX EX '*_"‘—i"_'—"—"“‘i '*_"‘—i"_'—"—"“‘i MIKE SULLIVAN MIKE SULLIVAN HARRIS COUNTY TAX ASSESSOR-COLLECTOR HARRIS COUNTY TAX ASSESSOR-COLLECTOR 1001 PRESTON AVE., SUITE 100 1001 PRESTON AVE., SUITE 100 HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002 Certiﬁed Owner: Certiﬁed Owner: Legal Description: Legal Description: COHEN JAYH COHEN JAYH LT8&TRS9B11D&12BLK428 LT8&TRS9B11D&12BLK428

1715 W ALABAMA ST OFC 3 1715 W ALABAMA ST OFC 3

SSBB SSBB

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

Legal Acres: Legal Acres: .2511 .2511 Acgount N0; Acgount N0; Parcel Address: 2113 BASTROP ST Parcel Address: 2113 BASTROP ST As of Date: As of Date: 11/01/2013 11/01/2013 APPR. DIST#: 0021460000008 APPR. DIST#: 0021460000008 Print Date: Print Date: 11/01/2013 11/01/2013 Printed By: LBCSOMOZA Printed By: LBCSOMOZA Cause No: 2013-16814 Suit 2010-06881 Jud Cause No: 2013-16814 Suit 2010-06881 Jud 2013 Value: 2013 Value: $79,454 $79,454 STATE OF TEXAS STATE OF TEXAS COUNTY OF HARRIS COUNTY OF HARRIS I, MIKE SULLIVAN, Tax Assessor-Collector in and for Harris County, Texas, do hereby certify this to be a I, MIKE SULLIVAN, Tax Assessor-Collector in and for Harris County, Texas, do hereby certify this to be a true and correct copy of the records of the H\a7is County Tax Ofﬁce, for the tax year(s) indicated. true and correct copy of the records of the H\a7is County Tax Ofﬁce, for the tax year(s) indicated. Witness my hand this Witness my hand this {I} {I} day of Kb day of Kb 20 (3 20 (3

.;\ﬂlI1itm,, .;\ﬂlI1itm,, y"fz2-..2;<_>..» y"fz2-..2;<_>..» as "9 as "9 6" 6"

MIKE SULLIVAN MIKE SULLIVAN

8 4' 8 4' ' ' Tax Assessor-Collector Tax Assessor-Collector Harris County Texas Harris County Texas

urnhlum, urnhlum, as as By /)1). By /)1). . *9IUQQI.H . *9IUQQI.H .V q."'6u" .V q."'6u" \ \ !Iu’,'§?.ﬁT‘:\\‘\ !Iu’,'§?.ﬁT‘:\\‘\ .‘,6\"‘$sess;;,, Q‘.‘. .‘,6\"‘$sess;;,, Q‘.‘. Deputy Deputy Page Page 3 of 3 of 3 3 *59 CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL ‘I ‘I 1"‘ 1"‘ 85 Co 85 Co

H4 H4

A)- A)- 11> 11> It It

if if TEX»? TEX»? HARRIS COUl\lT“$ HARRIS COUl\lT“$

MIKE SULLIVAN MIKE SULLIVAN HARRIS COUNTY TAX ASSESSOR-COLLECTOR HARRIS COUNTY TAX ASSESSOR-COLLECTOR 1001 PRESTON AVE., SUIT 1001 PRESTON AVE., SUIT E 100 E 100 I I Q Q

HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002

Certiﬁed Owner: Certiﬁed Owner: Legal Description: Legal Description: COHEN JAYH COHEN JAYH LTS6&7&TRS 8A& 12 BLK6 LTS6&7&TRS 8A& 12 BLK6

1715 W ALABAMA ST OFC 2 1715 W ALABAMA ST OFC 2

HOLMAN OUTLOT 40 HOLMAN OUTLOT 40

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

Legal Acres: Legal Acres: .3545 .3545 Account N0: 019-190-000-0006 Account N0: 019-190-000-0006 Pa"¢¢lAd<l"§§= 0 STUART ST Pa"¢¢lAd<l"§§= 0 STUART ST AS of Date: AS of Date: ll/01/2013 ll/01/2013 APPR. DIST#: 0191900000006 APPR. DIST#: 0191900000006 Print Date: Print Date: ll/01/2013 ll/01/2013 Printed By LBCSOMOZA Printed By LBCSOMOZA Cause No: 2013-16814 Suit Cause No: 2013-16814 Suit 2013 Value: 2013 Value: $339,680 $339,680

I I

TTTTITT WT” TTTTITT WT” '5 MI '5 MI

I I Base Base

I I

Appraised Appraised Tax Tax TRX TRX . . Penalties & Penalties & Collectio Collectio TotalI TotalI Year Year Value Value UnitsI UnitsI D119 D119 ‘ ‘ I I Interest Interest Fee Fee

M: M:

2004 2004 $0.00 I $0.00 I $270,200 I $270,200 I I I $2,592.30I $2,592.30I $6,781.45 $6,781.45 1 1 $4,189.15 $4,189.15 l l $648251 $648251 $1,695.83 I $1,695.83 I $0.00 I $0.00 I $1,047.58 $1,047.58 $53.79I $53.79I $0.00 $0.00 $140.71 1 $140.71 1 $86.92 $86.92 I I $27.12I $27.12I $0.00 $0.00 $70.94 $70.94 $43.82 $43.82 $308.37I $308.37I $0.00 I $0.00 I $806.70j $806.70j $498.33 $498.33 ‘ ‘ $10.20I $10.20I $0.00 I $0.00 I $26.69 I $26.69 I $16.49 $16.49 I I $155.60 $155.60 $0.00 I $0.00 I $407.05 $407.05 $251.45 $251.45 I I $1,053.78 $1,053.78 $2,756,691 $2,756,691 $1,702.91 $1,702.91 $0.00 1 $0.00 1 0'1-l>-l>-l>-B-l=-J> 0'1-l>-l>-l>-B-l=-J> —'0ObbJ|\)>—~® —'0ObbJ|\)>—~® ix ix .ﬁ13t61=|5r6r20114_;___ H .ﬁ13t61=|5r6r20114_;___ H $4, $4, $12,686.06 I $12,686.06 I 849.41 849.41 $7,836.65 $7,836.65 $0.00 $0.00 //2 //2 ‘2005 ‘2005 $285,640I $285,640I 1 1 $0.00 $0.00 $7,166.75 $7,166.75 $4,267.58 $4,267.58 $2,899.17 $2,899.17 $0.00 I $0.00 I $1,736.00 . $1,736.00 . $1,026.85 $1,026.85 $709.15 $709.15 $0.00 I $0.00 I $144.24, $144.24, $85.32 $85.32 $58.92 $58.92 -b-P>-O -b-P>-O $0.00 $0.00 $64.00 1 $64.00 1 42 42 $37.86 $37.86 $26.14 $26.14

$0.00 I $0.00 I

$834.28 I $834.28 I 43 43 $493.48 $493.48 $340.80 $340.80 $0.00 I $0.00 I $27.30 $27.30 44 44 $16.15 $16.15 $11.15 $11.15 $0.00 $0.00 $415.76 $415.76 48 48 $245.92 $245.92 $169.84 $169.84 $0.00 $0.00 $2,811.13 I $2,811.13 I 61 61 I I $1,148.34 $1,148.34 $1,662.79 $1,662.79 sﬁitliiis 1812005; sﬁitliiis 1812005; ss,s6s.s1 ss,s6s.s1 “$7,835.95 “$7,835.95 $0.00" $0.00" $13,199.46 I $13,199.46 I ii ii "$8188.58 I "$8188.58 I 52,9502 52,9502 $0.00 I $0.00 I 2006 2006 $308,800“ I $308,800“ I I I $3,933.56 $3,933.56

$807.61 $807.61 $0.00 I $0.00 I $1,880.26 I $1,880.26 I 40 40 $1,072.59 $1,072.59 $65.05. $65.05. $0.00 I $0.00 I $151.44 I $151.44 I 41 41 $86.39 $86.39 I I $26.14‘ $26.14‘ $0.00 I $0.00 I $60.85 $60.85 42 42 $34.71 $34.71 I I $385.70 $385.70 $0.00 $0.00 $897.91 $897.91 43 43 $512.21 $512.21 I I $12.63 $12.63 $0.00 I $0.00 I $29.40 I $29.40 I 44 44 $16.77 $16.77 $191.03 $191.03 $0.00 ~ $0.00 ~ 48 48 $253.69 $253.69 $444.72 I $444.72 I $0.00 $0.00 $3,013.92 j $3,013.92 j $1,294.64 $1,294.64 61 61 $1,719.28 $1,719.28 I I A 85,744.88 A 85,744.88 »-9. 82,529.20 »-9. 82,529.20 $0.00 $0.00 $13,374.0sTI $13,374.0sTI Subtotals for 2006: Subtotals for 2006: . . I I $386,000 $386,000 $3,214.69‘ $3,214.69‘ $3,806I20 1 $3,806I20 1 “$0.00 “$0.00 $7,020.89 I $7,020.89 I

no o Q no o Q $1,090.53 $1,090.53 $0.00 $0.00 $2,381.71 I $2,381.71 I 40 40 $1,291.18 $1,291.18

I I

$86.32I $86.32I I I $0.00 I $0.00 I $188.52 $188.52 4 1 4 1 $102.20 $102.20 _ ' _ ' . . $39.94 $39.94 $0.00 $0.00 $87.23 . $87.23 . I I 42 42 $47.29 $47.29 I I $534.05 $534.05 $0.00 ‘ $0.00 ‘ $1,166.36I $1,166.36I 43 43 $632.31 $632.31 $16.27 $16.27 $0.00 $0.00 $35.53 j $35.53 j 44 44 $19.26 $19.26

1.88 1.88 Page Page

CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

*60 *1 *1 .4’ ‘:8 11$»8 19° .4’ ‘:8 11$»8 19° w E’ w E’ 1 1 1' 1' 9 /77~: ’< 9 /77~: ’<

‘ ‘ MIKE SULLIVAN MIKE SULLIVAN HARRIS COUNTY TAX ASSESSOR-COLLECTOR HARRIS COUNTY TAX ASSESSOR-COLLECTOR 1001 PRESTON AVE., SUITE 100 1001 PRESTON AVE., SUITE 100 HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002 Certiﬁed Owner: Certiﬁed Owner: Legal Description: Legal Description: COHEN JAYH COHEN JAYH LTS6&7&TRS 8A& 1213186 LTS6&7&TRS 8A& 1213186

1715 W ALABAMA ST OFC 2 1715 W ALABAMA ST OFC 2

HOLMAN OUTLOT 40 HOLMAN OUTLOT 40

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

Legal Acres: Legal Acres: .3545 .3545 Account N0: 019-190-000-0006 Account N0: 019-190-000-0006 Par“! Addressl Par“! Addressl 9 STUART 5T 9 STUART 5T AS Of Date: AS Of Date: 11/0l/2013 11/0l/2013 APPR. DIST#Z 0191900000006 APPR. DIST#Z 0191900000006 Print Date: Print Date: 1 1/01/2013 1 1/01/2013 Printed By LBCSOMOZA Printed By LBCSOMOZA Cause No: 2013-16814 Suit Cause No: 2013-16814 Suit Z013 Value: Z013 Value: $339 680 $339 680

7 7 77 77 ~-_ ~-_ __ __ _ _ ___., ___., 1 1 Base Base TH TH Penalties & Penalties & 031166116 031166116 1 1 1 1 Appraised Appraised Tax Tax Q Q-8‘.1 Q Q-8‘.1 1Year 1Year Value Value Units Units D119 D119 Interest Interest Fees , Fees , 2007 2007 $256.89 $256.89

$561.05 1 $561.05 1 $304.16 $304.16 $0.00 1 $0.00 1 $1,789.11 $1,789.11 $3,907.42 1 $3,907.42 1 $2,118.31 $2,118.31 $0.00 ‘ $0.00 ‘ 05-$> -oo 05-$> -oo f%§‘is=£11>161=1.§@?6r 2007: f%§‘is=£11>161=1.§@?6r 2007: $15,348.-111 $15,348.-111 $7,027.80 $7,027.80 $8,320.91 $8,320.91 $0.00 $0.00 12008 12008 $463,200 $463,200 $4,105.181 $4,105.181 $4,269.39 $4,269.39 $0.00 $0.00 $8,374.57 $8,374.57 1 1 ‘ ‘ $1,381.391 $1,381.391 $1,436.64 $1,436.64 $0.00 1 $0.00 1 $2,818.03 $2,818.03

1 1 $109521 $109521 $1 13.90 $1 13.90 $0.00 1 $0.00 1 $223.42 $223.42 $62931 $62931 $65.45 $65.45 $0.00 1 $0.00 1 $128381 $128381 $709.27 $709.27 1 1 $681.99 $681.99 $0.00 1 $0.00 1 $1,391.261 $1,391.261 $20.73 $20.73 $21.56 $21.56 $0.00 1 $0.00 1 $42.29 1 $42.29 1 1 1 $328.04 $328.04 $341.16 $341.16 $0.00 1 $0.00 1 $669,201 $669,201 ‘ ‘ $2,266.95 $2,266.95 $2,357.63 $2,357.63 $0.00 1 $0.00 1 $4,624.58 1 $4,624.58 1

o\-|>4>J>4>J=-4>- o\-|>4>J>4>J=-4>- --oo~|>w~—-o’-‘ --oo~|>w~—-o’-‘ 11w1¢?2.1 11w1¢?2.1 , , 81111161613 81111161613 1 1 $8,956.73 $8,956.73 $9,315.00 $9,315.00 $0.00 $0.00 120091 120091 1500,0400 1500,0400 1 1 H I H I In $1,060.75 In $1,060.75 $0.00 1 $0.00 1 $2,011.19 1 $2,011.19 1 $950.44 $950.44 40 1 40 1 $359.70 $359.70 $0.00 1 $0.00 1 $682001 $682001 $322.30 $322.30 41 ‘ 41 ‘ $26801 $26801 $0.00 1 $0.00 1 $50.81 § $50.81 § $24.0| $24.0| 1 1 $15001 $15001 $0.00 1 $0.00 1 $28.44 $28.44 $13.44 $13.44 $176.22‘ $176.22‘ $0.00 1 $0.00 1 $334.12 $334.12 $l57.90 $l57.90 $5.55 $5.55 $0.00 1 $0.00 1 $10.52 1 $10.52 1 $4.97 $4.97 $84.571 $84.571 $0.00 1 $0.00 1 $160341 $160341 $75.77 $75.77 1 1 $585761 $585761 $0.00 $0.00 $1,110.601 $1,110.601 O\J>~J>-$>-K>~ O\J>~J>-$>-K>~ $524.84 $524.84 —-O0-J>~LMl\) —-O0-J>~LMl\) 84,388.02 1 84,388.02 1 Subtotals for 2009: Subtotals for 2009: $2,314.35 $2,314.35 $2,073.67 $2,073.67 $0.00 $0.00 1 20111 1 20111 $225,000 A $225,000 A 1 1 $289.18 $289.18 $175.82 $175.82 $0.00 $0.00 $465001 $465001 40 40 $97791 $97791 $59.46 $59.46 $0.00 $0.00 $157.25 1 $157.25 1 41 41 $7.02 $7.02 $4.27 $4.27 $0.00 1 $0.00 1 $11.29 1 $11.29 1

1 42 ‘ 1 42 ‘ $4.64 $4.64 $2.82 $2.82 $0.00 1 $0.00 1 $7.46 1 $7.46 1 1 1 ‘ ‘ 1 43 1 43 $48041 $48041 $29.20 $29.20 $0.00 1 $0.00 1 $77.24 1 $77.24 1 * * 44 1 44 1 $1.651 $1.651 $1.00 $1.00 $0.00 1 $0.00 1 $2.65 $2.65 1 1 48 48 $24.30 $24.30 $14.77 $14.77 $0.00 $0.00 $39.07 1 $39.07 1 $0.00 1 $0.00 1 $256781 $256781 61 61 $159.69 $159.69 $97.09 $97.09 Subtotals fur 2011; Subtotals fur 2011; 8682.31 I 8682.31 I $1,016.74i $1,016.74i $0.00 .8» $0.00 .8» _ _ -.. -.. “"°"?,,w “"°"?,,w $478,6401 $478,6401 1 1 1 1 $4,987.63 $4,987.63 $2,314.26 $2,314.26 $0.00 1 $0.00 1 $7,301.89 1 $7,301.89 1 O >_8 O >_8 1 40 1 1 40 1 $1,725.69 $1,725.69 $800.72 $800.72 $0.00 1 $0.00 1 $2,526.41 1 $2,526.41 1

_____S_ _____S_

41 41 $121.12‘ $121.12‘ $56.20 $56.20 $0.00 $0.00 $177.32 1 $177.32 1 LiLL). LiLL). 1.88 1.88

CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

*61 85 Co 85 Co 0 0 <z~ <z~ _, ,6/4;‘ _, ,6/4;‘

M4» M4»

9‘ 9‘ '4 '4 ’Ex A9 ’Ex A9

MIKE SULLIVAN MIKE SULLIVAN HARRIS COUNTY TAX ASSESSOR-COLLECTOR HARRIS COUNTY TAX ASSESSOR-COLLECTOR 1001 PRESTON AVE., SUITE 100 1001 PRESTON AVE., SUITE 100 HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002 Certiﬁed Owner: Certiﬁed Owner: Legal Description: Legal Description: COHEN JAYH COHEN JAYH LTS6&7&TRS 8A& 12 BLK6 LTS6&7&TRS 8A& 12 BLK6

1715 W ALABAMA ST OFC 2 1715 W ALABAMA ST OFC 2

HOLMAN OUTLOT 40 HOLMAN OUTLOT 40

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

Legal Acres: Legal Acres: .3545 .3545 Account No: 019-190-000-0006 Account No: 019-190-000-0006 P=""lAdd"§§= 0 STUART 5T P=""lAdd"§§= 0 STUART 5T AS of Date: AS of Date: 11/01/2013 11/01/2013 APPR. DIST#: 0191900000006 APPR. DIST#: 0191900000006 Print Date: Print Date: 11/01/2013 11/01/2013 Printed By LBCSOMOZA Printed By LBCSOMOZA Cause No: 2013-16814 Suit Cause No: 2013-16814 Suit 2013 Value: 2013 Value: $339,680 $339,680

Base Base Tax Tax Appraised Appraised Tax Tax Penalties & Penalties & Collection Collection Total Total Year Year Value Value Units Units DI-W DI-W Interest Interest Fees Fees 20121 20121 $84171 $84171 $0.001 $0.001 $123.23 $123.23

$39.06 $39.06 $785461 $785461 $0.001 $0.001 $1,149.91 1 $1,149.91 1 $364.45 $364.45 -bkwk) -bkwk) $28.53 $28.53 $0.001 $0.001 $41775 $41775 44 44 $13.24 $13.24 $0.001 $0.001 $613.43 1 $613.43 1 $419011 $419011 $194.42 $194.42 $2,754.251 $2,754.251 $0.00 1 $0.00 1 $4,032.23 $4,032.23 $1,277.98 $1,277.98 O‘\J> '—'OO O‘\J> '—'OO I I $0.00 $0.00 sis 966.19 1 sis 966.19 1 .1s\s; -8 ,\:\ §\tbtotals for 2012: .1s\s; -8 ,\:\ §\tbtotals for 2012: $10,905.86 $10,905.86 $5,060.33 $5,060.33 4 4 \ \ $437 $437 1 1 = = . . TOTAL AMOUNT DUE: TOTAL AMOUNT DUE: $45,794.85 $45,794.85 $48,456.14 $48,456.14 $0.00 $0.00 $94,250.99 $94,250.99 Tax Unit Codes: Tax Unit Codes: 1 1 I-Iouston I.S.D. I-Iouston I.S.D. 40 Harris County 40 Harris County 41 41 Harris County Flood Control Dist Harris County Flood Control Dist 42 42 Port of I-Iouston Authority Port of I-Iouston Authority 43 Harris County Hospital District 43 Harris County Hospital District 44 Harris County Dept. of Education 44 Harris County Dept. of Education 48 Houston Community College System 48 Houston Community College System 61 City of Houston 61 City of Houston

IF YOU ARE 65 YEARS OF AGE OR OLDER OR ARE DISABLED AND THE PROPERTY DESCRIBED IN THIS DOCUMENT IS YOUR RESIDENCE HOMESTEAD 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 HA VE TO A POSTPONEMENT IN THE PAYMENT OF THESE YOU SHOULD CONTACT THE APPRAISAL DISTRICT REGARDING ANY ENTITLEMENT YOU MAY HA VE TO A POSTPONEMENT IN THE PAYMENT OF THESE TAXES. TAXES.

Partial Statement: Other Years and Tax Units may be due Partial Statement: Other Years and Tax Units may be due Totals By Tax Unit 1 Totals By Tax Unit 1 _,_ _,_ , , __ __ __ __ __ __ _ _ _ _ ___ ___ Tax Tax Base Base Penalties Penalties Collection Collection

TOT TOT

Units Units & Interest & Interest Fees Fees Tax Due Tax Due Total Total 1 1 $22,110.92 $22,110.92 $23,906.40 $23,906.40 $0.00 $0.00 $46,017.32 $46,017.32 40 40 $6,820.17 $6,820.17 $7,057.32 $7,057.32 $0.00 $0.00 $13,877.49 $13,877.49 41 41 $528.54 1 $528.54 1 $559.21 $559.21 $0.00 $0.00 $1,087.75 $1,087.75

$284.45 $284.45 42 42 $286.08 $286.08 $0.00 $0.00 $570.53 $570.53

$3,397.15 Q $3,397.15 Q

43 43 $3,260.63 $3,260.63 $0.00 $0.00 $6,657.78 $6,657.78 $109.44 $109.44 44 44 $106.71 $106.71 $0.00 $0.00 $216.15 $216.15 cw Total cw Total 40f 44 40f 44 $11,002.13 $11,002.13 $1 1,407.57 $1 1,407.57 $0.00 $0.00 $22,409.70 $22,409.70 1 1 48 48 $1,629.28 $1,629.28 $1,681.34 $1,681.34 $0.00 $0.00 $3,310.62 $3,310.62 1 1 61 61 $11,052.52 $11,052.52 $11,460.83 $11,460.83 $0.00 $0.00 $22,513.35 $22,513.35 TOTAL AMOUNT DUE: TOTAL AMOUNT DUE: $45,794.85 $45,794.85 $48,456.14 $48,456.14 $0.00 $0.00 $94,250.99 $94,250.99 188 188

Pag C Pag C

CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

*62 v v <95 Coo <95 Coo

Q- Q-

1+13.9 1+13.9 *"1'@:* *"1'@:*

‘ ‘ -"=55. -"=55. -..‘. -..‘. EX EX 7 J‘ 7 J‘ Y Y

COHEN JAY H COHEN JAY H

LTS6&7&TRS8A&l2BLK6 LTS6&7&TRS8A&l2BLK6 1715 W ALABAMA ST OFC 2 1715 W ALABAMA ST OFC 2 HOLMAN OUTLOT 40 HOLMAN OUTLOT 40

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

Legal Acres: Legal Acres: .3545 .3545 Account No: 019-190-000-0006 Account No: 019-190-000-0006 Parcel Address: Parcel Address: 0 STUART ST 0 STUART ST As of Date: As of Date: 11/01/2013 11/01/2013 APPR. DIST#: 0191900000006 APPR. DIST#: 0191900000006 P 'nt D P 'nt D ri ri ate: ate: 11/01/2013 11/01/2013 Printed By LBCSOMOZA Printed By LBCSOMOZA Cause N0: 2013-16814 Suit Cause N0: 2013-16814 Suit

2013 Value: 2013 Value: $339,680 $339,680 STATE OF TEXAS STATE OF TEXAS COUNTY OF HARRIS COUNTY OF HARRIS I MIKE SULLIVAN Tax Assessor Collector in nd fo H I MIKE SULLIVAN Tax Assessor Collector in nd fo H , , , , - - a a r arris County, Texas, do hereby certify this to be a r arris County, Texas, do hereby certify this to be a ue an correct copy of the records of the Harris County Tax Ofﬁce, for the tax year(s) indicated. ue an correct copy of the records of the Harris County Tax Ofﬁce, for the tax year(s) indicated. tr tr d d ' ' Witness my hand this Witness my hand this day of day of 1/ 1/ 20 20

‘tsiulﬂtnrq, ‘tsiulﬂtnrq,

MIKE SULLIVAN MIKE SULLIVAN

1'4,-1' 1'4,-1' Tax Assessor-Collector Tax Assessor-Collector :6 :6 mu mu Harris County Texas Harris County Texas 1 1 B, B,

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CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

*63 CO 6 14,, CO 6 14,, D D é... M "4 é... M "4

E. E.

-k -k *5 *5 MIKETLIVAN I MIKETLIVAN I HARRIS COUNTY TAX ASSESSOR-COLLECTOR HARRIS COUNTY TAX ASSESSOR-COLLECTOR 1001 PRESTON AVE., SUITE I00 1001 PRESTON AVE., SUITE I00 I I

HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002

E E Certiﬁed Owner: Certiﬁed Owner: Legal Description: Legal Description:

COHEN JAY H COHEN JAY H

LT 3 BLK 34 LT 3 BLK 34

1715 W ALABAMA ST OFC 2 1715 W ALABAMA ST OFC 2

WASHINGTON TERRACE WASHINGTON TERRACE

HOUSTON TX 77098-2807 HOUSTON TX 77098-2807

Legal Acres: Legal Acres: .1326 .1326 Account N0; Account N0; Parcel Address: 3010 ALABAMA ST Parcel Address: 3010 ALABAMA ST As of Date As of Date 11/01/2013 11/01/2013 APPR. DIST#: 0611680340003 APPR. DIST#: 0611680340003 Print Date: Print Date: 11/01/2013 11/01/2013 Printed By LBCSOMOZA Printed By LBCSOMOZA Cause No Cause No 2013-16814 Sui 2013-16814 Sui 2013 Value: 2013 Value: $31 500 $31 500

1 1 Base Base 1 1 Tax Tax 1 1 T6611 T6611 Appraised Appraised Tax 1 Tax 1 Penalties & Penalties & Collection Collection Due Due 1 1 Year Year Value Value Units Units Interest Interest Fees Fees $16,330 $16,330 $101.03 1 $101.03 1 $0.00 1 $0.00 1 $163.55 1 $163.55 1 $62.52 $62.52

NOO NOO

$25.28 1 $25.28 1 $0.00 1 $0.00 1 $40.92 $40.92 $15.64 $15.64 $2.10 $2.10 $0.00 1 $0.00 1 $3.40 $3.40 $1.30 $1.30 $0.00 j $0.00 j $1.70 1 $1.70 1 $0.65 $0.65 $1.05 i $1.05 i $0.00 $0.00 $19.46 1 $19.46 1 $7.44 $7.44 $12.02. $12.02. $0.41 ; $0.41 ; $0.00 $0.00 $0.66 1 $0.66 1 $0.25 $0.25 $6.07 3 $6.07 3 $0.00 $0.00 $9.82 1 $9.82 1 $3.75 $3.75 1 1 $41.08 $41.08 $66.50 $66.50 $25.42 $25.42 $0.00 $0.00 $306.01 1 $306.01 1 Subtotii Subtotii $116.97 $116.97 “£139.04 “£139.04 $0.00 $0.00 $327.38 ' $327.38 ' $0.00 $0.00 $549791 $549791 $25,988 $25,988 $222.41 $222.41 $79.72 $79.72 $0.00 I $0.00 I $133.88 3 $133.88 3 $54.16 $54.16 $6.62 $6.62 $0.00 1 $0.00 1 $11.12 ‘ $11.12 ‘ $4.50 $4.50 $2.94 $2.94 $0.00 $0.00 $4.94 j $4.94 j $2.00 $2.00 $38.31 $38.31 $0.00 $0.00 $64.34 $64.34 $26.03 $26.03 $0.00 1 $0.00 1 $2.08 1 $2.08 1 $0.84 $0.84

$1.24 $1.24 $19.09 $19.09 $0.00 $0.00 $32.06 1 $32.06 1

$12.97 $12.97 $129.09 $129.09 $0.00 $0.00 $216.79 1 $216.79 1 $87.70 $87.70 81.015001 81.015001 Subtot Subtot $4/10.61 $4/10.61 $604.39 . $604.39 . $0.00 $0.00 $415.62 $415.62 $728.59 1 $728.59 1 $37,538 $37,538 $312.97 $312.97 $0.00 $0.00 $198671 $198671 $113.33 $113.33 $85.34 $85.34 $0.00 $0.00 $9.14 $9.14 $16.02 $16.02 $6.88 $6.88 $0.00 $0.00 $3.66 $3.66 $6.42 $6.42 $2.76 $2.76 $0.00 $0.00 $54.12 $54.12 $94.87f $94.87f $40.75 $40.75 $0.00 $0.00

4L4Q\_ 4L4Q\_

$1.77 $1.77 $3.10 ~ $3.10 ~ $1.33 $1.33 $0.00 $0.00 $26.81 I $26.81 I $0.00 1 $0.00 1 $47.00; $47.00; $20.19 $20.19 $181.65 $181.65 $318.44 1 $318.44 1 $136.79 $136.79 $0.00 $0.00 - ~$a01e1.0 - ~$a01e1.0 Subtotals for 2006: Subtotals for 2006: .. .. , , V V 4 4 $607.01 $607.01 $0 00 $0 00 $141311 $141311 ... ... ‘ ‘ ’ ’ ' ' $409.09 1 $409.09 1 $0.00 $0.00 $754.60 $754.60 $46,200 $46,200 $345.51 $345.51 $138.76 1 $138.76 1 $0.00 1 $0.00 1 $255.961 $255.961 $1 17.20 $1 17.20 $10.99 i $10.99 i $20271 $20271 $9.28 $9.28 $0.00 1 $0.00 1 $5.08 $5.08 $9.37 1 $9.37 1 $0.00 $0.00 $4.29 $4.29 $67.96 $67.96 $0.00 1 $0.00 1 $125.361 $125.361 $57.40 $57.40 $3.80 1 $3.80 1 44 1 44 1 $1.74 $1.74 $2.06 1 $2.06 1 $0.00 $0.00 1?; 1?;

CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

*64 x5 Co x5 Co "1 "1 ‘.1 ‘.1 Eiiw xv‘ Eiiw xv‘ ‘I. ‘I. 1+ 1+ TEXA9 TEXA9 MIKE SULLIVAN MIKE SULLIVAN HARRIS COUNTY TAX ASSESSOR-COLLECTOR HARRIS COUNTY TAX ASSESSOR-COLLECTOR 1001 PRESTON AVE., SUITE 100 1001 PRESTON AVE., SUITE 100 HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002 Certiﬁed Owner: Certiﬁed Owner: Legal Description: Legal Description:

COHEN JAY H COHEN JAY H

LT 3 BLK 34 LT 3 BLK 34

1715 W ALABAMA ST OFC 2 1715 W ALABAMA ST OFC 2

WASHINGTON TERRACE WASHINGTON TERRACE

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

Legal Acres: Legal Acres: .1326 .1326 Account N0; Account N0; P?ll"C€l A(l(II‘€SSZ 3010 ALABAMA ST P?ll"C€l A(l(II‘€SSZ 3010 ALABAMA ST As of Date: As of Date: 11/01/2013 11/01/2013 APPR. DIST#: 0611680340003 APPR. DIST#: 0611680340003 Print Date: Print Date: 11/01/2013 11/01/2013 Printed By LBCSOMOZA Printed By LBCSOMOZA Cause No: 2013-16814 Cause No: 2013-16814 2013 Value: 2013 Value: $31,500 $31,500

Totals By Tax Unit Totals By Tax Unit M _ _ M _ _ 1 1 Base Base Penalties Penalties Collection Collection 1 1 1 1 Tax Tax Fees Fees L L Total Total ‘ ‘ Units Units Tax Due Tax Due & Interest & Interest __i__ __i__ , , _ _ ,__ ,__

$2,885.68 $2,885.68 . . $1,293.59 $1,293.59 $1,592.09 $1,592.09 $0.00 $0.00

-A -A

$862.20 $862.20 40 40 $390.64 $390.64 $471.56 $471.56 $0.00 $0.00 $68.72 $68.72 $31.05 $31.05 $37.67 $37.67 $0.00 $0.00 41 41 $32.52 $32.52 1 1 42 42 $14.85 $14.85 $17.73 $17.73 $0.00 $0.00 $418.52 $418.52 1 1 $1 $1 $189.80 $189.80 $228.72 $228.72 $0.00 $0.00 43 43 ‘ ‘

$5.98 $5.98 $7.24 $7.24 $0.00 $0.00 $13.22 $13.22 1 1

$632.32 $632.32

1£“lI9£a_'. .- ...§91f‘.f‘..-..__ 1£“lI9£a_'. .- ...§91f‘.f‘..-..__ $762.92 $762.92 $0.00‘? ‘_ $0.00‘? ‘_ __ 524 __ 524 en en ..__...__.__._. ....$O‘00 ..__...__.__._. ....$O‘00 ‘ ‘ 4s 4s 1 1 $92.47 $92.47 $1 1 1.72 $1 1 1.72 en;-‘N1...»o\oP. G en;-‘N1...»o\oP. G 61 61 T T $635.59 1 $635.59 1 $0.00 $0.00 1 1 $1,402.28 $1,402.28 $766.69 $766.69

I I

TOTAL AMOUNT DUE: TOTAL AMOUNT DUE: $2,653.97 $2,653.97 $3,233.42 $3,233.42 $0.00 $0.00 $5,887.39 $5,887.39 STATE OF TEXAS STATE OF TEXAS COUNTY OF HARRIS COUNTY OF HARRIS I, MIKE SULLIVAN, Tax Assessor-Collector in and for Harris County, Texas, do hereby certify this to be a I, MIKE SULLIVAN, Tax Assessor-Collector in and for Harris County, Texas, do hereby certify this to be a true and correct copy of the records of the Harris County Tax Ofﬁce, for the tax year(s) indicated. true and correct copy of the records of the Harris County Tax Ofﬁce, for the tax year(s) indicated.

1 5 M M ... /3 1 5 M M ... /3 Witness my hand this Witness my hand this _ _ day of day of 0 0 ¢;u1tam|;,, . ¢;u1tam|;,, . c.0\~*~E¢r "% c.0\~*~E¢r "% ,........,_ 0,, ,........,_ 0,,

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=1»19‘ =1»19‘ ‘YZWH ‘YZWH 5 COUNTY 5 COUNTY mI mI Tn'==a=:. Tn'==a=:. MIKE SULLIVAN MIKE SULLIVAN HARRIS COUNTY TAX ASSESSOR-COLLECTOR HARRIS COUNTY TAX ASSESSOR-COLLECTOR 1001 PRESTON AVE., sum; 100 1001 PRESTON AVE., sum; 100 H I B A H I B A

HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002

Certiﬁed Owner: Certiﬁed Owner: Legal Description: Legal Description:

COHEN JAY H COHEN JAY H

LT 10 BLK 6 LT 10 BLK 6

I715 W ALABAMA ST OFC 3 I715 W ALABAMA ST OFC 3

HOLMAN OUTLOT 65 HOLMAN OUTLOT 65

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

Base Base 1 1 Appraised Appraised Tax Tax Ta! Ta! Penalties & = Penalties & = Collection 1 Collection 1 Total Total Year‘ Year‘ Value Value Units1 Units1 D119 D119 Interest Interest Fees 1 Fees 1 $239179 $239179 $0.00 1 $0.00 1 $32,500 $32,500 1 1 M" M" $558.23 $558.23 $318.44 ' $318.44 ' I\) OO I\) OO $65.39 $65.39 $0.00 1 $0.00 1 $86.84 $86.84 $152.23 $152.23 1 1 $6.98 $6.98 $0.00 1 $0.00 1 $5.26 $5.26 $12.24 $12.24 $0.00 1 $0.00 1 $2.11 $2.11 1 1 $2. 80 $2. 80 $4.91 $4.91 $31.22 $31.22 $0.00 $0.00 1 1 $41 .46 $41 .46 $72.68 $72.68 Jr-J>-I>-l> u)I\>>—'O Jr-J>-I>-l> u)I\>>—'O 1 1 $1.38 $1.38 $0.00 1 $0.00 1 $1.04 $1.04 44 44 $2.42 $2.42 $20.53 $20.53 $0.00 1 $0.00 1 $15.46 $15.46 48 48 $35.99 $35.99 $139.19 $139.19 $104.81 $104.81 $0.00 , $0.00 , 61 61 $244.00 $244.00

MMMMMMMMML MMMMMMMMML

$0.00 $0.00 $1,082.70 1 $1,082.70 1 11 11 Subtotals for 2006: Subtotals for 2006: $465.08 $465.08 $617.62 $617.62 $119.83 1 $119.83 1 $0.00 T ___ $221.04 $0.00 T ___ $221.04 1 20071 1 20071 $25,000 $25,000 1 1 $101.21 $101.21 $40.66 $40.66 $0.00 $0.00 $75.00 $75.00 40 40 $34.34 $34.34 $3.22 $3.22 $0.001 $0.001 $5.94 $5.94 41 41 $2.72 $2.72 $0.00. $0.00. $2.75 $2.75 42 42 $1.26 $1.26 $1.49 $1.49 $19.90 $19.90 $0.00 1 $0.00 1 $36.71 $36.71 $16.81 $16.81 43 43 $0.61 1 $0.61 1 $0.00 $0.00 $1.121 $1.121 $0.51 $0.51 44 44 $9.57 $9.57 $0.00 1 $0.00 1 $17.66 1 $17.66 1 48 48 $8.09 $8.09 $66.69 $66.69 $0.00 1 $0.00 1 $123.02 $123.02 $56.33 $56.33 61 61 1:1 1:1 __M§9.~99 W 948% __M§9.~99 W 948% Subtotals for 2007: Subtotals for 2007: $221.27 $221.27 $261.97 $261.97 $010.6. $010.6. 1 1 ‘“$3<I66o ‘“$3<I66o $165.02 1 $165.02 1 ‘ 2008 ‘ 2008 1 1 $158.67 $158.67 $0.00 $0.00 $108.91 . $108.91 . 40 40 $53.39 $53.39 $55.52 1 $55.52 1 $4.41 § $4.41 § $0.00 1 $0.00 1 $8.65 i $8.65 i 41 41 $4.24 $4.24 $2.53 5 $2.53 5 $0.00 $0.00 $4.96 1 $4.96 1 42 42 $2.43 $2.43 $27.41 1 $27.41 1 $0.00 $0.00 $53.77 $53.77 43 43 $26.36 $26.36 $0.85 1 $0.85 1 $0.00 $0.00 $1.661 $1.661 44 44 $0.81 $0.81 $13191 $13191 $0.00 $0.00 $25871 $25871 48 48 $12.68 $12.68 $91121 $91121 $0.00 $0.00 $178 74‘ $178 74‘ . . 1 1 61 61 $87.62 $87.62 T T Subtotals for 2008: Subtotals for 2008: $346.20 $346.20 ’ /1’; 1 ’ /1’; 1 1. Q 1. Q $0.00 $0.00 $706.25 $706.25 WTT$11M58.6M8MM WTT$11M58.6M8MM $142. 17 $142. 17 TMTiMWvi$0i‘00 TMTiMWvi$0i‘00 $300.85 1 $300.85 1 $30,000 $30,000 1 1 IQ OC> IQ OC> $0.00 $0.00 $102.021 $102.021 40 40 $53.81 $53.81 $48.21 $48.21

MM MM

1 1 1 1 41 41 $4.01 1 $4.01 1 $0.00 $0.00 $7.61 $7.61 $3.60 $3.60 $2.24 $2.24 $2.01 $2.01 $0.00 $0.00 $4.25 $4.25 -I>~ I\) -I>~ I\) $26361 $26361 $23.62 $23.62 $0.00 A $0.00 A $49.98 $49.98 1 1 ‘431 ‘431 1 1 1 1 44 44 $0.83’ $0.83’ $0.74 $0.74 $0.00 $0.00 $1 .57 $1 .57 1.88 1.88

CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

*66 Q35 coo Q35 coo 1» 1» €__> MMrEX As Mi €__> MMrEX As Mi MIKE SULLIVAN MIKE SULLIVAN HARRIS COUNTY TAX ASSESSOR-COLLECTOR HARRIS COUNTY TAX ASSESSOR-COLLECTOR I001 PRESTON AVE., SUITE 100 I001 PRESTON AVE., SUITE 100 HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002 Legal Description: Legal Description: Certiﬁed Owner: Certiﬁed Owner: COHEN JAY H COHEN JAY H

LT 10 BLK 6 LT 10 BLK 6 1715 W ALABAMA ST OFC 3 1715 W ALABAMA ST OFC 3 HOLMAN OUTLOT 65 HOLMAN OUTLOT 65

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

Legal Acres: Legal Acres: .1148 .1148 Parcel Address: 2311 WHEELER ST Parcel Address: 2311 WHEELER ST Account No: 019-268-000-0010 Account No: 019-268-000-0010 Print Date: Print Date: 11/01/2013 11/01/2013 Printed By: LBCSOMOZA Printed By: LBCSOMOZA AS Of D8801 AS Of D8801 11/01/2013 11/01/2013 APPR. DIST#! 0192680000010 APPR. DIST#! 0192680000010 2013 Value: 2013 Value: $37,500 $37,500 Cause No: 2013-16814 Suit Cause No: 2013-16814 Suit

Base Base 1 1 1 1 Appraised Appraised TEX TEX T1“ T1“ Penalties & Penalties & Collection Collection Total 1 Total 1 Year Year Value Value Units; Units; DI"? DI"? [um-¢§| 1 [um-¢§| 1 Fggs Fggs 1 1 2009 2009 “Mm “Mm $12.65 $12.65 $11.34; $11.34;

$0.00 $0.00 $23.99 $23.99 $0.00 $0.00 $87.63. $87.63. $78.52 1 $78.52 1 $166.15 $166.15 Ct-l> >—IOO Ct-l> >—IOO $346.21 $346.21 $310.21 $310.21 $0.00 $0.00 $656.42 $656.42 20111 20111 $32,500 $32,500 1 1 $28.94. $28.94. $21.76 $21.76 $0.00 $0.00 $50.70 $50.70 1 1 1 1 40 40 $9.70 $9.70 $7.29 $7.29 $0.00 $0.00 $16.99 $16.99 1 1 $0.73 $0.73 $0.55 $0.55 $0.00 $0.00 $1.28 $1.28 1 1 $0.511 $0.511 $0.38 I $0.38 I $0.00 $0.00 $0.89 $0.89 $4.80 $4.80 $3.61 $3.61 $0.00 $0.00 $8.41 $8.41 $0.17 $0.17 $0.13 $0.13 $0.00 $0.00 $0.30 $0.30 $2.30 $2.30 $1.73 I $1.73 I $0.00 $0.00 $4.03 $4.03 $0.00 $0.00 1 1 $15.96 $15.96 $12.00 - $12.00 - $27.96 $27.96 O\<l>-l'>~J>-li-l=~ —-ooJ>wM—- O\<l>-l'>~J>-li-l=~ —-ooJ>wM—- $63.11 $63.11 $47.45 $47.45 $0.00 $0.00 $110.56 1 $110.56 1 20111 20111 $32,500 $32,500 1 1 $28921 $28921 $17.58 $17.58 $0.00 $0.00 $46.50 $46.50 $9.781 $9.781 $5.95 $5.95 $0.00 $0.00 $15.73 $15.73 $0.701 $0.701 $0.43 $0.43 $0.00 $0.00 $1.13 $1.13 $0.461 $0.461 $0.28 $0.28 $0.00 $0.00 $0.74 $0.74

-l>-l>-lkl\)—*O -l>-l>-lkl\)—*O 1 1 43 43 ‘ ‘ $0.00 $0.00 $7.72 $7.72 $4.801 $4.801 $2.92 1 $2.92 1 1 1 $0.171 $0.171 $0.111 $0.111 $0.00 $0.00 $0.28 $0.28 1 1 44 44 1 1 $2.43 $2.43 $1.48 1 $1.48 1 $0.00 $0.00 $3.91 $3.91 1 1 48 48 1 1

1 1 $15.971 $15.971 $9.71 1 $9.71 1 $0.00 $0.00 $25.68 1 $25.68 1 61 61 1 M Subtotals §§f12l_)_11__1f__ 1 M Subtotals §§f12l_)_11__1f__ $63-23 $63-23 ____1 _ $38.46 ____1 _ $38.46 $0.00 $0.00 $101.69 $101.69 ‘ 20121 ‘ 20121 $37,500 1 $37,500 1 1 1 $250831 $250831 $116381 $116381 $0.00 $0.00 $367.21 $367.21 $86791 $86791 $40.27 1 $40.27 1 $0.00 $0.00 $127.06 $127.06 1 1 ‘ ‘ . 40 . 40 $6.091 $6.091 $2.83 1 $2.83 1 $0.00 $0.00 $8.92 $8.92 1 1 41 41

1 42 1 42 $4.23 1 $4.23 1 $1.96 $1.96 1 1 $0.00 $0.00 $6.19 1 $6.19 1 1 1 43 43 $39.50; $39.50; $18.33 : $18.33 : $0.001 $0.001 $57.83 1 $57.83 1 1 1 44 44 $1.431 $1.431 $0.66 . $0.66 . $0.00 $0.00 $2.09 1 $2.09 1 $21,071 $21,071 $9.78 $9.78 $0.00 $0.00 $30.85 $30.85 1 1 1 1 48 48 1 1 1 1 61 61 $138511 $138511 $64.27 1 $64.27 1 $0.00 $0.00

$202.78 $202.78 1 1 8681666 161~z012= 8681666 161~z012= $546.45 " $546.45 " .4» .4» ' ' ' ' .$802.9s~1 .$802.9s~1 TOTAL AMOUNT DUE: TOTAL AMOUNT DUE: $2,053.55 $2,053.55 $1,890.24 $1,890.24 $0.00 $0.00 $3,943.79 $3,943.79 1.88 1.88 Page Page 2 of 2 of 4 4

CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

*67 * ’ * ’ x5 Co x5 Co <z~ <z~ 0 0 .- _;§ .- _;§ ‘ ¢ ‘ ¢ ‘ft174$ ‘ft174$ It)\L It)\L iii? iii? X -1 3,- U‘ X -1 3,- U‘ MIKE SULLIVAN MIKE SULLIVAN HARRIS COUNTY TAX ASSESSOR-COLLECTOR HARRIS COUNTY TAX ASSESSOR-COLLECTOR 1001 PRESTON AVE., SUITE 100 1001 PRESTON AVE., SUITE 100 HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002 Certiﬁed Owner: Certiﬁed Owner: Legal Description: Legal Description:

COHEN JAY H COHEN JAY H

LT 10 BLK 6 LT 10 BLK 6

1715 W ALABAMA ST OFC 3 1715 W ALABAMA ST OFC 3

HOLMAN OUTLOT 65 HOLMAN OUTLOT 65

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

Legal Acres: Legal Acres: .1148 .1148 Account N0; Account N0; Parcel Address: 2311 WHEELER ST Parcel Address: 2311 WHEELER ST As of Date: As of Date: 11/01/Z013 11/01/Z013 APPR. DIST#: 0192630000010 APPR. DIST#: 0192630000010 Print Date: Print Date: 11/01/2013 11/01/2013 Printed By: LBCSOMOZA Printed By: LBCSOMOZA Cause N0: 2013-16314 Suit Cause N0: 2013-16314 Suit 2013 Vﬂlllﬂl 2013 Vﬂlllﬂl $37,500 $37,500 Tax Unit Codes: Tax Unit Codes:

1 Houston I.S.D. 1 Houston I.S.D. 40 Harris County 40 Harris County 41 Harris County Flood Control Dist 41 Harris County Flood Control Dist 42 42 Port of Houston Authority Port of Houston Authority 43 Harris County Hospital District 43 Harris County Hospital District 44 Harris County Dept. of Education 44 Harris County Dept. of Education 48 Houston Community College System 48 Houston Community College System 61 City of Houston 61 City of Houston

IF YOU ARE 65 YEARS OF AGE OR OLDER OR ARE DISABLED AND THE PROPERTY DESCRIBED IN THIS DOCUMENT IS YOUR RESIDENCE HOMESTEAD, 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 HA VE TO A POSTPONEMENT IN THE PAYMENT OF THESE YOU SHOULD CONTACT THE APPRAISAL DISTRICT REGARDING ANY ENTITLEMENT YOU MAY HA VE TO A POSTPONEMENT IN THE PAYMENT OF THESE TAXES. TAXES.

Partial Statement: Other Years and Tax Units may be due Partial Statement: Other Years and Tax Units may be due IQ§.3.|$_B_Y..T?.¥U.HjI._. IQ§.3.|$_B_Y..T?.¥U.HjI._. . . . ._ . ._ _.... _.... 7 7 ...._-_ ...._-_ I I Tax Tax Base Base Penalties Penalties Collection Collection ‘ ‘ Units Units Tax Due Tax Due & Interest & Interest E E Fees Fees Total Total

1TV_~-_.... ..__ _.. -4 _._____._7..___ M WM MW _. . ...._._. ._ L.___..._.___._.L . _ .. A . _ _.__ 1TV_~-_.... ..__ _.. -4 _._____._7..___ M WM MW _. . ...._._. ._ L.___..._.___._.L . _ .. A . _ _.__

l l $967.04 $967.04 $0.00 $0.00 $1,868.22 $1,868.22 $901 . I 8 $901 . I 8 $597.94 1 $597.94 1 40 40 $313.20 $313.20 $0.00 $0.00 $284.74 $284.74 41 41 $23.75 $23.75 $0.00 $0.00 $45.77 $45.77 ‘ ‘ $22.02 $22.02 42 42 $13.24 $13.24 $0.00 $0.00 $24.69 $24.69 $1 1.45 $1 1.45 43 43 $149.85 $149.85 $0.00 $0.00 $287.10 1 $287.10 1 $137.25 $137.25 44 44 $4.96 $4.96 $0.00 $0.00 $9.44 $9.44 $4.48 $4.48

iiCW Total iiCW Total 40 " 44 40 " 44 $505f.00ﬂ‘ $505f.00ﬂ‘ W W "V "V $459.94 $459.94 $0.00 $0.00 $964.94 ‘ $964.94 ‘ 48 48 $74.68 $74.68 $0.00 $0.00 $142.30 ‘ $142.30 ‘ $67.62 $67.62 61 61 1 1 $506.83 $506.83 $0.00 $0.00 $968.33 $968.33 $46 I .50 $46 I .50

TOTAL AMOUNT DUE: TOTAL AMOUNT DUE: $2,053.55 $2,053.55 $1 ,890.24 $1 ,890.24 $0.00 $0.00 $3,943.79 $3,943.79 .1.88 .1.88 a e a e

CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

*68 t t

J J

<2-‘S Co <2-‘S Co E-ii ﬁg! E-ii ﬁg! it-IL it-IL TEX A5 TEX A5

MIKE SULLIVAN MIKE SULLIVAN HARRIS COUNTY TAX ASSESSOR-COLLECTOR HARRIS COUNTY TAX ASSESSOR-COLLECTOR 1001 PRESTON AVE., SUITE 100 1001 PRESTON AVE., SUITE 100 HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002 Certiﬁed Certiﬁed Owner: Owner: Legal Description: Legal Description:

COHEN JAYH COHEN JAYH

LT 10 BLK6 LT 10 BLK6 HOLMAN OUTLOT 65 HOLMAN OUTLOT 65 1715 W ALABAMA ST OFC 3 1715 W ALABAMA ST OFC 3 HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

Legal Acres: Legal Acres: .1148 .1148 Account N0; Account N0; Parcel Address: 2311 WHEELER ST Parcel Address: 2311 WHEELER ST As of Date: As of Date: 11/01/2013 11/01/2013 APPR. DIST#: 0192680000010 APPR. DIST#: 0192680000010 'Print Date: 'Print Date: 11/01/2013 11/01/2013 Printed By LBCSOMOZA Printed By LBCSOMOZA Cause No: 2013-16814 Suit Cause No: 2013-16814 Suit 2013 Value: 2013 Value: $37,500 $37,500 STATE OF TEXAS STATE OF TEXAS COUNTY OF HARRIS COUNTY OF HARRIS ounty, Texas, do hereby certify this to be a ounty, Texas, do hereby certify this to be a L L MIKE SULLIVAN, Tax Assessor-Collector in and for Harris C MIKE SULLIVAN, Tax Assessor-Collector in and for Harris C true and correct copy of the records of the Harris County Tax Ofﬁce, for the tax year(s) indicated. true and correct copy of the records of the Harris County Tax Ofﬁce, for the tax year(s) indicated. Witness my hand this Witness my hand this day of day of V V 20 20

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MIKE SULLIVAN MIKE SULLIVAN

Tax Assessor-Collector Tax Assessor-Collector Harris County Texas § Harris County Texas §

~"'-.....-""Q 1-Q-- ~"'-.....-""Q 1-Q-- m m “ggﬂlllt “ggﬂlllt ""'a|§;:ii1'\n\““‘ ""'a|§;:ii1'\n\““‘ sf:-§§§.§€ C‘.‘ sf:-§§§.§€ C‘.‘ u.‘Y u.‘Y I I +¢,'§""1i*'éii=J"d6““§‘ +¢,'§""1i*'éii=J"d6““§‘ W ‘< W ‘< "Inmnm\\\“ "Inmnm\\\“ D¢P"tY D¢P"tY Page Page 4 4 *69 1 1 CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL 4' 4' 15 Co 15 Co <3 <3 0 0 4-113‘ 4-113‘ to to COUNTY COUNTY 1. ><~ 1. ><~ 1 1 1 1 /77 /77 MIKE SULLIVAN MIKE SULLIVAN 1* 1* HARRIS COUNTY TAX ASSESSOR-COLLECTOR HARRIS COUNTY TAX ASSESSOR-COLLECTOR 1001 PRESTON AVE. SUITE 100 1001 PRESTON AVE. SUITE 100 HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002 l B A l B A Certiﬁed Owner: Certiﬁed Owner: Legal Description: Legal Description: COHEN JAY H COHEN JAY H LTS 9 & 10 BLK1 LTS 9 & 10 BLK1 1715 W ALABAMA ST OFC 3 1715 W ALABAMA ST OFC 3 SMITH FURNITURE co SEC 2 SMITH FURNITURE co SEC 2

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

Legal Acres: Legal Acres: .1435 .1435 Accgunt N9; Accgunt N9; Parcel Address: 3506 NAGLE ST Parcel Address: 3506 NAGLE ST AS of Date: AS of Date: 11/01/2013 11/01/2013 APPR. DIST#: 0192030010009 APPR. DIST#: 0192030010009 Print Date: Print Date: 11/01/2013 11/01/2013 Printed By LBCSOMOZA Printed By LBCSOMOZA Cause No: 2013-16814 Suit Cause No: 2013-16814 Suit 2013 Value; 2013 Value; $50,000 $50,000

Base Base Appraised Appraised Tax Tax TKX TKX Penalties & Penalties & Collection Collection Total 1 Total 1 Unigs Unigs Due Due Interest Interest Fees 1 Fees 1 Year Year Value Value 2006 2006 $34,375 $34,375 1 1 1 1 1 1 $184.46 $184.46 $244.96 $244.96 $0.00 1 $0.00 1

$429.42 $429.42 40 1 40 1 $50.30 $50.30 $66.80 $66.80 $0.00 1 $0.00 1 $117.10 $117.10 $5.32 $5.32 $0.00 1 $0.00 1 1 1 $4.05 $4.05 $9.43 $9.43 1 1 $1.63 $1.63 $2.16 I $2.16 I $0.001 $0.001 $3.79 $3.79 $31.90 $31.90 $0.00 » $0.00 » 1 1 $24.02 $24.02 $55.92 $55.92 Jr-l>-I> u:I\>~—- Jr-l>-I> u:I\>~—- 44 1 44 1 $0.78 $0.78 $1.03 $1.03 $0.00 1 $0.00 1

$1.81 $1.81 48 48 $11.90 $11.90 $15.81 $15.81 $0.001 $0.001 $27.71 $27.71 61 61 1 1 $80.63 $80.63 $107.07 $107.07 $0.00 1 $0.00 1 $187.70 $187.70 4;: 4;: $832.88 $832.88 ii ii Siggtgtals for 2006: Siggtgtals for 2006: $357.77 $357.77 $475.11 $475.11 $0.00 $0.00 T $34,250 T $34,250 1 1 1 1 $143.14 $143.14 $169.47 $169.47 $0.001 $0.001 $312.61 $312.61

IO C) O IO C) O 40 40 $48.55 $48.55 $57.48 $57.48 $0.00 1 $0.00 1 $106.03 $106.03 41 1 41 1 $3.84 $3.84 $4.55 $4.55 $0.00 $0.00 $8.39 $8.39 42 1 42 1 $1.78, $1.78, $2.1 1 $2.1 1 $0.00 1 $0.00 1 $3.89 $3.89 43 43 $23.781 $23.781 $28.16 $28.16 $0.00 1 $0.00 1

$51.94 $51.94 $0.721 $0.721 $0.85 $0.85 $0.00 $0.00 $1.57 $1.57 $11.441 $11.441 $13.54 $13.54 $0.00 1 $0.00 1 $24.98 $24.98

I I $79.66? $79.66? $173.98 $173.98 $94.32 $94.32 $0.00 1 $0.00 1 O\-l>-|=~ -100-Ii- O\-l>-|=~ -100-Ii-

MMMMMMMM MMMMMMMM

M_1A1_$370.48 M_1A1_$370.48 $0.00 $0.00 $63339 $63339 Subtotals for 2007: Subtotals for 2007: $312.91 $312.91 41 41 $31,"25'0'1'“'“ 1 $31,"25'0'1'“'“ 1 1 1 $107941 $107941 $1 12.26 $1 12.26 $0.00 1 $0.00 1 $220.20 $220.20 40 40 $36.321 $36.321 1 1 $37.77 i $37.77 i $0.00 1 $0.00 1 $74.09 $74.09

. 41 . 41 $2.881 $2.881 $3.00 $3.00 $0.00 1 $0.00 1 $5.88 $5.88 ^[1] 1 ^[1] 1 1 1 1 42 1 42 $1.66 $1.66 $1.72 $1.72 $0.00 $0.00 $3.38 $3.38 1 43 1 43 $17.93 $17.93 $18.65 $18.65 $0.00 1 $0.00 1 $36.58 $36.58

44 44 $0.54 $0.54 $0.56 $0.56 $0.00 1 $0.00 1 $1.10 $1.10 48 1 48 1 $8.62 $8.62 $8.96 $8.96 $0.00 j $0.00 j

$17.58 1 $17.58 1 $61.98 $61.98 $0.00 $0.00 61 I 61 I $59.60 $59.60 $121.58 $121.58 1 1 1 1 $235.49 W $235.49 W $4 $4 391 391 " " ' Subtotals for 2008: ' Subtotals for 2008: _;.;.1;.;aa%.“i"“‘$°'°° _;.;.1;.;aa%.“i"“‘$°'°° .-.-.....L.____._..........I§F‘~ 1 .-.-.....L.____._..........I§F‘~ 1 ‘ ‘ 20091 20091 $43,750; $43,750; 1 WiiiiiiiiiiiMM 1 WiiiiiiiiiiiMM $252541 $252541 $226.27 $226.27 $0.00 $0.00 $478.81 1 $478.81 1 1 40 1 40 $85631 $85631 $76.73 $76.73 $0.00 1 $0.00 1 $162.36, $162.36, ‘ 41 ‘ 41 $6.381 $6.381 $5.72 - $5.72 - $0.001 $0.001 $12.10 $12.10

42 1 42 1 $3.571 $3.571 $3.20 $3.20 $0.00 1 $0.00 1 $6.77 $6.77 43 1 43 1 $41951 $41951 $37.59 $37.59 $0.00 1 $0.00 1

$79.54 1 $79.54 1 44 44 $1.321 $1.321 $1.19 $1.19 $0.00 1 $0.00 1 $2.51 $2.51 1.88 1.88 Pa ge1of4 Pa ge1of4 *70 .. .. .. .__.._.W....4- _......._._.Ls......LM_...... .. .__.._.W....4- _......._._.Ls......LM_...... _ _ ...........».....__2 ,.. ...........».....__2 ,.. ._._._E‘_4..._ <I><f'>> _..._....._..._._. ._._._E‘_4..._ <I><f'>> _..._....._..._._. . . . . ...,..._...w1\.-~ »»- » ...,..._...w1\.-~ »»- » -=» -=» 4»- 4»- ~~» ~ ~~» ~

CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

‘ ‘ x5 Co x5 Co 0 0 wig, wig, .- .- =811>“ =811>“ ‘1 ‘1 PEXP-9 PEXP-9 MIKE SULLIVAN MIKE SULLIVAN HARRIS COUNTY TAX ASSESSOR-COLLECTOR HARRIS COUNTY TAX ASSESSOR-COLLECTOR 1001 PRESTON AVE., SUITE 100 1001 PRESTON AVE., SUITE 100 HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002 Certiﬁed Owner: Certiﬁed Owner: Legal Description: Legal Description: COHEN JAYH COHEN JAYH LTS9& 10 BLK1 LTS9& 10 BLK1 1715 W ALABAMA ST OFC 3 1715 W ALABAMA ST OFC 3 SMITH FURNITURE co SEC 2 SMITH FURNITURE co SEC 2

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

Legal Acres : Legal Acres : .1435 .1435 Accgunt N0; Accgunt N0; Parcel Address: 3506 NAGLE ST Parcel Address: 3506 NAGLE ST As of Date: As of Date: 11/01/2013 11/01/2013 APPR. DIST#:0192030010009 APPR. DIST#:0192030010009 Print Date: Print Date: 11/01/2013 11/01/2013 Printed By: LBCSOMOZA Printed By: LBCSOMOZA Cause No: 2013-16814 Suit Cause No: 2013-16814 Suit 2013 Value: 2013 Value: $50,000 $50,000

1.1 Year 1.1 Year Base Base 1 1 Appraised Appraised Tax Tax TRX TRX 1 1 Penalties & Penalties & Collection Collection Tota Tota Value Value 1Units1 1Units1 D119 D119 Interest Interest Fees Fees 1 48 1 1 48 1 I $20.13 I $20.13 $0.00 1 $0.00 1 $38.17 1 $38.17 1 $18.04 $18.04 $0.00 1 $0.00 1 1 61 1 61 $139.45 $139.45 $264.40 $264.40 $124.95 $124.95 1 1 *1~9~259§J *1~9~259§J $0.00 $0.00 _ _ Q Q SubtotaIs&f.or 2009: SubtotaIs&f.or 2009: $550.97 $550.97 $493.69 $493.69 $18.08 $18.08 $0.00 1 $0.00 1 $31.68 $31.68 12010; 12010; $45,313i $45,313i 1 1 $13.60 $13.60 $6.07 $6.07 $0.00 $0.00 $10.63 $10.63 140 140 $4.56 $4.56 1 1 $0.45 $0.45 $0.00 $0.00 $0.79 $0.79 $0.34 $0.34 * * $0.33 $0.33 $0.00 1 $0.00 1 $0.58 $0.58 $0.25 $0.25 1 1 $3.00 $3.00 $0.00 $0.00 $5.26 1 $5.26 1 $2.26 $2.26 1 1 $0.10 $0.10 $0.00 1 $0.00 1 $0.18 1 $0.18 1 $0.08 $0.08 $1.45 $1.45 $0.00 1 $0.00 1 $2.54 $2.54 $1.09 $1.09 $9.98 $9.98 $0.00 1 $0.00 1 $17.48 $17.48 $7.50 $7.50 --oo-l>w|\>-- --oo-l>w|\>-- O5-|>-I>J>~J>-I> O5-|>-I>J>~J>-I>

“ , “ , I sub¢»:ar§’f6é2010= I sub¢»:ar§’f6é2010= $39.46 $39.46 $69.14 $69.14 $29.68 $29.68 $0.00 $0.00 ..__._.';'.<....... ..__._.';'.<....... ...... ...... _ _ >' Wk >' Wk 1 201111“ 1 201111“ $45,313‘ $45,313‘ 1 1 $18.09 $18.09 $0.00 $0.00 $29.09 $29.09 $1 1.00 $1 1.00 1 40 1 40 $6.11 $6.11 $0.00 . $0.00 . $9.83 $9.83 $3.72 $3.72 41 41 $0.441 $0.441 $0.00 1 $0.00 1 $0.71 $0.71 $0.27 $0.27 42 1 42 1 $0.29 $0.29 $0.00 1 $0.00 1 $0.47 $0.47 $0.18 $0.18 43 j 43 j $3.00 $3.00 $0.00 $0.00 $4.82 $4.82 $1.82 $1.82 44; 44; $0.101 $0.101 $0.00 $0.00 $0.16 1 $0.16 1 $0.06 $0.06 48 1 48 1 $1.51 $1.51 $0.00 $0.00 $2.42 $2.42 $0.91 $0.91 I I $9.99 $9.99 $0.00 $0.00 $16.07 $16.07 61 ‘ 61 ‘ $6.08 $6.08 $0.00 $0.00 I I $63.57 1 $63.57 1 Subtotals for 2011: Subtotals for 2011: $39.53 $39.53 ' 9 ' 9 $24.04 $24.04 12012“ 12012“ $56,250 $56,250 1 1 $467.71 $467.71 A$68'4i'7'3i1 A$68'4i'7'3i1 $217.02 $217.02 $0.00 $0.00 1 1 40 40 . . $161.83 $161.83 $236.92 $236.92 $75.09 $75.09 $0.00 $0.00 1 1 ‘ 41 ‘ 41 $16.63 1 $16.63 1 1 1 $11.36 $11.36 $5.27 $5.27 $0.00 $0.00 42 1 42 1 $7.89 $7.89 $3.67 1 $3.67 1 $1 1.56 1 $1 1.56 1 $0.00 $0.00 43 43 $73661 $73661 $34.18 1 $34.18 1 $107.84 $107.84 $0.00 $0.00 44 44 $2.671 $2.671 $1.24; $1.24; $3.91 1 $3.91 1 $0.00 $0.00 48 48 $39.29; $39.29; $18.23 $18.23 $57.52 1 $57.52 1 $0.00 $0.00 1 1 61 61 $258281 $258281 1. 1. _. _. $119841 $119841 $378.12 1 $378.12 1 $0.00 $0.00 . .

- -

114 114 - - » Subtotals for 2012: » Subtotals for 2012: 022 69 022 69 $1,497.23 $1,497.23 .; .; ;"»i1‘\>?3°;:\”US$0.00 ;"»i1‘\>?3°;:\”US$0.00 $2,112.44 $2,112.44 $0.00 $0.00 TOTAL AMOUNT DUE: TOTAL AMOUNT DUE: $2,558.82 $2,558.82 $4,671.26 $4,671.26 1.88 1.88 Page Page 2 2

CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

*71 x9 Co x9 Co 42> 42> QQ QQ W W AL AL 1» 1» 1'.’ 1'.’ 7 6* g 7 6* g

EX EX MIKE SULLIVAN MIKE SULLIVAN HARRIS COUNTY TAX ASSESSOR-COLLECTOR HARRIS COUNTY TAX ASSESSOR-COLLECTOR 1001 PRESTON AVE., SUITE 100 1001 PRESTON AVE., SUITE 100 HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002 Certiﬁed Owner: Certiﬁed Owner: Legal Description: Legal Description: COHEN JAY H COHEN JAY H LTS 9& 10 BLK1 LTS 9& 10 BLK1 1715 W ALABAMA ST OFC 3 1715 W ALABAMA ST OFC 3 SMITH FURNITURE co SEC 2 SMITH FURNITURE co SEC 2

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

Legal Acres: Legal Acres: .1435 .1435 Account N0; Account N0; Parcel Address: 3506 NAGLE ST Parcel Address: 3506 NAGLE ST AS of Date: AS of Date: 11/01/2013 11/01/2013 APPR. DIST#: 0192030010009 APPR. DIST#: 0192030010009 Print Date: Print Date: 11/01/2013 11/01/2013 Printed By LBCSOMOZA Printed By LBCSOMOZA Cause N0: 2013-16814 Suit Cause N0: 2013-16814 Suit 2013 Value: 2013 Value: $50,000 $50,000 Tax Unit Codes: Tax Unit Codes:

IF YOU ARE 65 YEARS OF AGE OR OLDER OR ARE DISABLED AND THE PROPERTY DESCRIBED IN THIS DOCUMENT IS YOUR RESIDENCE HOMESTEAD, 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 MA Y HA VE TO A POSTPONEMENT IN THE PA YMENT OF THESE YOU SHOULD CONTACT THE APPRAISAL DISTRICT REGARDING ANY ENTITLEMENT YOU MA Y HA VE TO A POSTPONEMENT IN THE PA YMENT OF THESE TAXES. TAXES.

Partial Statement: Other Partial Statement: Other ' ' Years and Tax Units may be due Years and Tax Units may be due

T_o_t_als By Tax Unit T_o_t_als By Tax Unit

Tax Tax Base Base Penalties Penalties Collection Collection Units Units Tax Due Tax Due & Interest & Interest Fees Fees . . Total Total

. . ‘ ‘ l l $1,191.96 $1,191.96 $994.58 $994.58 $0.00 $0.00 $2,186.54 $2,186.54 1 1 40 40 $394.81 $394.81 $0.00 $0.00 $716.96 $716.96 $322.15 $322.15

41 41 $29.40 $29.40 $0.00 $0.00 $53.93 $53.93 $24.53 $24.53 42 42 $17.15 $17.15 $0.00 $0.00 $30.44 $30.44 $13.29 $13.29 43 43 $187.34 $187.34 $154.56 $154.56 $0.00 $0.00 $341.90 $341.90

1 1 44 44 $6.23 $6.23 ; ; $5.01 $5.01 $0.00 $0.00 $11.24 $11.24 1 CW:1:ota1A _i0— 44 1 CW:1:ota1A _i0— 44 $634.93*§_ My $634.93*§_ My $519.54 $519.54 $0.00 $0.00 $1,154.47 $1,154.47 4s 4s $94.34 1 $94.34 1 $170.92 $170.92 $76.58 $76.58 $0.00 $0.00 61 61 $637.59 1 $637.59 1 $521.74 $521.74 $0.00 $0.00 $1,159.33 $1,159.33 TOTAL AMOUNT DUE: TOTAL AMOUNT DUE: $2,558.82 $2,558.82 $2,112.44 $2,112.44 $0.00 $0.00 $4,671.26 $4,671.26 188 188 a a 3 3

*72 , , CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

I‘ I‘

“.453, “.453, *AB‘ *AB‘ ..._1'7 ..._1'7 ITo ITo ‘Ts<9 ‘Ts<9 EX EX MIKE SULLIVAN MIKE SULLIVAN HARRIS COUNTY TAX ASSESSOR-COLLECTOR HARRIS COUNTY TAX ASSESSOR-COLLECTOR 1001 PRESTON AVE., SUITE 100 1001 PRESTON AVE., SUITE 100 HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002 Certiﬁed Owner: Certiﬁed Owner: Legal Description: Legal Description: COHEN JAYH COHEN JAYH LTS9& 10 BLK1 LTS9& 10 BLK1

1715 W ALABAMA ST OFC 3 1715 W ALABAMA ST OFC 3

SMITH FURNITURE CO SEC 2 SMITH FURNITURE CO SEC 2

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

Legal Acres: Legal Acres: . 1435 . 1435 Account N0; Account N0; ParcelAddress: 3506 NAGLE ST ParcelAddress: 3506 NAGLE ST As of Date: As of Date: 11/01/2013 11/01/2013 APPR. DIST#: 0192030010009 APPR. DIST#: 0192030010009 Print Date: Print Date: 11/01/2013 11/01/2013 Printed By: LBCSOMOZA Printed By: LBCSOMOZA Cause No : 2013-16814 Suit Cause No : 2013-16814 Suit 2013 Value: 2013 Value: $50,000 $50,000

STATE OF TEXAS STATE OF TEXAS COUNTY OF HARRIS COUNTY OF HARRIS I, MIKE SULLIVAN, Tax Assessor-Collector in and for Harris County, Texas, do hereby certify this to be a I, MIKE SULLIVAN, Tax Assessor-Collector in and for Harris County, Texas, do hereby certify this to be a true and correct copy of the records of the Harris County Tax Ofﬁce, for the tax year(s) indicated. true and correct copy of the records of the Harris County Tax Ofﬁce, for the tax year(s) indicated. Witness my hand this Witness my hand this day of day of V 20_/3 V 20_/3

. ;m|nam,,% . ;m|nam,,% f“=<>.es<-we» f“=<>.es<-we» * * MIKE SULLIVAN MIKE SULLIVAN Tax Assessor-Collector Tax Assessor-Collector Harris Coun Texas Harris Coun Texas

V O V O

-.,_________,- >1»4°~ -.,_________,- >1»4°~ S y S y “g\\iIllI§u~ #25-I-E353? “g\\iIllI§u~ #25-I-E353?

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Read the detailed case summary

CASE NO. 01-14-00914-CV

JAY COHEN,

MIDTOWN MANAGEMENT DISTRICT, ET AL,

IDENTITY OF THE PARTIES AND COUNSEL

TABLE OF CONTENTS

B.

INDEX OF AUTHORITIES

STATEMENT REGARDING ORAL ARGUMENT

STATEMENT OF THE CASE

STATEMENT OF FACTS

SUMMARY OF THE ARGUMENT

PROPERLY ISSUED.

“HOUSTON INDEPENDENT SCHOOL DISTRICT (HOUSTON ISD)”

II. APPELLANT’S ISSUES HAVE NO MERIT

CONCLUSION AND PRAYER FOR RELIEF

LINEBARGER GOGGAN

ATTORNEYS FOR APPELLANT

CERTIFICATE OF COMPLIANCE

CERTIFICATE OF SERVICE

CASE NO. 01-14-00914-CV

JAY COHEN,

MIDTOWN MANAGEMENT DISTRICT, ET AL,

APPELLEES’ APPENDIX

LIST OF DOCUMENTS

3

7

FILED IN

FINAL TRIAL

JAY COHEN (

FINAL TRIAL

DARLENE STEIN

FINAL TRIAL

APPEARANCES

SBN 24009764

SBN 00797872

DARLENE STEIN

FINAL TRIAL

DARLENE STEIN

FINAL TRIAL

(P R O C E E D I N G S)

DARLENE STEIN

FINAL TRIAL

DARLENE STEIN

DARLENE STEIN

DARLENE STEIN, CSR

DARLENE STEIN

CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

1715 W ALABAMA ST OFC 3 1715 W ALABAMA ST OFC 3

HOUSTON TX 77098-2807 HOUSTON TX 77098-2807

$1,488.85 I $1,488.85 I

$39.70 I $39.70 I

$0.00 I $0.00 I

$3.63 I $3.63 I

$6.35 I $6.35 I

I I

1715 W ALABAMA ST OFC 3 1715 W ALABAMA ST OFC 3

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

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CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

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1715 W ALABAMA ST OFC 3 1715 W ALABAMA ST OFC 3

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

MIKE SULLIVAN MIKE SULLIVAN

H4 H4

HOUSTON, TEXAS 77002 HOUSTON, TEXAS 77002

1715 W ALABAMA ST OFC 2 1715 W ALABAMA ST OFC 2

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

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CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

1715 W ALABAMA ST OFC 2 1715 W ALABAMA ST OFC 2

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

_____S_ _____S_

CERTIFIED DELINQUENT TAX STATEMENT DETAIL CERTIFIED DELINQUENT TAX STATEMENT DETAIL

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1715 W ALABAMA ST OFC 2 1715 W ALABAMA ST OFC 2

HOUSTON, TX 77098-2807 HOUSTON, TX 77098-2807

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