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Mary Ann Castro v. Manuel Castro
04-14-00785-CV
| Tex. App. | Sep 15, 2015
|
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Case Information

*1 In the Fourth Court Of Appeals

Fourth Court Of Appeals District

San Antonio Texas Bexar County

Maryann Castro

In the COURT OF ABREAS AT SAN ANTONIO. TEXAS

2015 SEP 15 PM 12: 09

KEIE B. HOTTLE. CLERK

V.

Manuel Castro

Re: Court Of Appeals Number: 04-14-00785-CV

Trial Court Case 2011 -Cl-15957

TO THE JUSTICES OF THE COURT:

MOTION FOR ORAL ARGUMENT

HERE COMES MARYANN CASTRO APPELLANT

THERE HAS BEEN CHANGES IN THE HOME MORTGAGE AND AS TO WHY THE AGREEMENT FOR FINAL DIVORCE SHOULD BE VOIDED AND REWRITTEN.

APPELLANT MARYANN CASTRO HAS FILED SUITE AGAINST THE HOME MORTGAGE SERVICER IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO TEXAS.

WHEN THE SIGNING TOOK PLACE IN OCT 2013 WHEN APPELLEE MANUEL CASTRO PUT THE HOME MORTGAGE IN BANKRUPTCY AND WHEN IT WAS RELEASED LIFT STAY FILED BY APPELLANT MARYANN CASTRO THE HOME MORTGAGE WAS TRANSFERRED TO A HOME MORTGAGE SERVICER BSI FINANCIAL ALSO KNOWN AS SN SERVICING. See e xhibit

THE HOME MORTGAGE WAS BEING OVERCHARGED BY THE SERVICER WHO WAS USING A RIDER RATE AND ALSO WRONGFULLY FORECLOSED ON SEPT 1,2015.

APPELLANT MARYANN CASTO HAS FILED A FRAUD AND FALSE STATEMENT AND WRONGFUL FORECLOSURE LAWSUITE AND THE STATUS IS PENDING IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION.

ALSO APPELLANT MARYANN CASTRQ IS NOT EMPLOYEED SHE IS DISABLED AND HAD MAJOR SURGERY AUG 10, 2015 SHE IS UNABLE TO FOR HERSELF AND IS NEEDING SPOUSAL MAINTENCE BEING THE SPOUSE OF APPELLEE MANUEL CASTRO FOR 29 YEARS SHE IS NEEDING ALIMONY.

REITIREMENT JOHNSON CONTROL AND KEOGH APPELLANT MARYANN CASTRO HAS THE RIGHT TO HER SHARE OF THESE TWO MARTIAL ASSETS AND IS NEEDING HER SHARE SHE DID NOT GIVE UP HER

*2

*3 RIGHT TO THE RETIREMENTS THAT ARE PART OF THE MARTIAL ASSETS WITHIN THE MARRIAGE OF MANUEL AND MARYANN CASTRO FOR 29 YEARS MARRIAGE ENDED DUE TO APPELLEE MANUEL CASTRO EXTRA MARTIAL AFFAIR WITH CHRISTINA PACHECO KNOWN AS TINA PACHECO THE NON SPOUSE MISTRESS WHO ATTACKED APPELLANT MARYANN CASTRO WITH FALSE CHARGES THAT WERE DROPPED IN ATASCOSA COURTHOUSE AND APPELLEE MANUEL CASTRO WAS PART OF THE ATTACK TO HARM APPELLANT MARYANN CASTRO.

APPELLEE BRIEF IS ALL HERE SAY AND WAS TYPED BY APPELLEE MANUEL CASTRO SISTER WHO IS PART OF CONFLICT TO HARM APPELLANT MARYANN CASTRO.

APPELLANT MARYANN CASTRO PRAYS FOR JUSTICE SEE EXHIBITA 4.5 e e e xhitat t is MARYANN CASTRO PRO-SE a/11/15 P.O. BOX 495

PLEASANTON TEXAS 78064 830-496-0133 ρ Ac A Hitude 2014 gmail.com CERTIFICATE OF SERVICE SENT TO APPELLEE CERTIFIED 9/14/15 MANUEL CASTRO 624 W.GOODWIN PLEASANTON TEXAS 78064

*4

EXHIBIT A

IN THE UNITED STATES District COURT For the Western District OF Texas San Antonio Division $ $ - Plaintiff Maryann Castro S Case no 5:15-CV-00715-DAE

VS Defendant SN Servicing MOTION NOT TO DISMISS CASE AGAINST SN SERVICING FOR WRONGFUL FORECLOSURE ON SEPT 1,2015 TO THE HONORABLE Judge of Said Court: HERE COMES PLAINTIFF MARYANN CASTRO AND MANUEL CASTRO WHO WERE WRONFULLY FORECLOSED BY BSI SN SERVICING ON SEPT 1,2015.

DEFENDANT SN SERVICING ALSO KNOWN AS BSI FINANCIAL WERE USING LOAN DOCUMENTS DEFECTIVE.

  1. RIDER RATE WHICH WAS FALSE THE SUBJECT PROPERTY WAS A FIXED RATE IN 2009 BECAME EFFECTIVE. SEE EXHIBIT A FIXED RATE PLAITIFF MARYANN CASTRO PROVIDED TO THE COURT ON JULY 2015 WHEN SHE FILED SUITE AGAINST SN SERVICING ALSO KNOWN AS BSI FINANCIAL.
  2. SN SERVICING PRESENTED TO THE WERSTRN DISTRICT COURT A DEFECTIVE LOAN DOCUMENT SHOWING RIDER RATE FALSELY OVERCHARGED HOMEMORTGAGE ,FEES EVEN FORECLOSED KNOWING THE PLAINTIFF MARYANN CASTRO AND MANUEL AND ARE IN LITIGATION IN COURT.EVEN KNOWING THE DEFECTIVE INSTRUMENT THE RIDER RATE WAS A FRAUD. s.e. exhibit 8
  3. SN SERVICING ATTORNEY SAMMY HOODA TOOK PART IN MORTGAGE FRAUD,FALSE STATEMENT,WRONGFUL FORECLOSURE KNOWING PLAINTIFF MARYANN CASTRO PRESENTED TO SN SERVICING ATTORNEY AND THE COURT THE TRUE INSTURMENT OF THE HOME MORTGAGE FIXED RATE THAT CHANGED IN 2009 AND PLAINTIFF MARYANN CASTRO SUBMITTED TO THE COURT SHOWING THE MORTGAGE HAD BEEN GETTING PAID IN THE AMOUNT OF OVER 13,000 WHICH WAS PAID TO BSI FINANCIAL KNOWN AS SN SERVICING AND WAS PAID BY THE BANKRUPTCY TRUSTEE AND STILL ATTORNEY SAMMY HOODA SN SERVICING LIED IN COURT SAYING ON AUG 31,2015 NO MORTGAGE PAYMENTS HAVE NOT BEEN PAID SINCE 2011 THAT WAS A UE AND FALSELY FORECLOSED ON SEPT 1,2015 KNOWING

*5 THE HOME 1501 OLIVE WAS IN LITIGATION IN FEDERAL COURT AND IS NOT DISMISSED AND HAD COPY OF FIXED RATE AND STATEMENT OF MORTGAGE PAYMENTS BEING PAID IN THE AMOUNT OF OVER 13,000 HOW IS THAT JUSTICE TO STILL FORECLOSE AS AN OFFICER OF THE COURT ATTORNEY SAMMY HOODA ABUSED PLAINTIFF MARYANN CASTRO BY WRONFULLY FORECLOSING ON SEPT1,2015. THAT IS CRIMINAL FRAUD AND PLAINTIFF MARYANN CASTRO AND MANUEL CASTRO HAVE SUFFERED AND ARE SEEKING DAMAGES DUE TO MORTGAGE FRAUD AND FALSE STATEMENTS AND WRONGFUL FORECLOSURE SUITE. 4. A SUITE FOR WRONGFUL FORECLOSURE 433SW.3D6S8(TEXAPP-HOUSTON[14 TH DISTRICT]2014,NOPET), 5. ALL DOCUMENTS LOAN FILED BY BSI FINANCIAL KNOWN AS SN SERVCING WERE DEFECTIVE SINCE WELSS FARGO HOME MORTGAGE TRANSFERRED TO BSI FINANCIAL KNOWN AS SN SERVCING (EG.,THE NOTE AND DEED OF TRUST IS IN THE NAME OF WELLS FARGO HOME MORTGAGE AND MANUEL CASTRO AND MARYANN CASTRO. FRAUD AND FALSE STATEMENT AND WRONGFUL FORECLOSURE WERE COMMITED ON OR ABOUT NOV 2013 AND CONTINUED ON SEPT 1,2015. 6. A NOTICE OF LIS PENDENS IS A WRITTEN NOTICE THAT A LAWSUITE HAS BEEN FILE CONCERNING REALESTATE, INVOLVING EITHER THE TITTLE TO THE PROPERTY OR A CLAIMED OWNERSHIP INTEREST IN IT.AND PLAINTIFF MARYANN CASTRO AND MANUEL CASTRO WILL FILE IMMEDIATELY DUE TO WRONGFUL FORECLOSURE BY SN SERVICING ALSO KNOWN AS BSI FINANCIAL THERE IS A LAWSUITE THAT HAS BEEN FILED BEGAN IN ATASCOSA COUNTY COURT ON OR ABOUT JULY 23,2015 DUE TO MORTGAGE FRAUD AND FALSE STATEMENT AND IS ACTIVE IN FEDERAL COURT SN SERVICING TRANSFERRED LAWSUITE CASE PLAINTIFF MARYANN CASTRO FILED AGAINST SN SERVCING KNOWN AS BSI FINANICAL WHO COLLECTED OVER 13,000 IN MORTGAGE FUNDS FROM THE BANKRUPTCY TRUSTEE AND DID NOT APPLY TO THE PRINCIPLE OF THE HOME MORTGAGE THEY SERVICER WERE OVERCHARGING USING THE DEFECTIVE MORTGAGE INTEREST RATE SHOWING RIDER RATE IN 2006 WAS VALID BUT CHANGED IN 2009 TO A FIXED RATE EVIDENCE HAS BEEN ENTERED IN COURT BSI SN SERVCING COMMITED MORTAGE FRAUD A CRIMINAL CIVIL RICO ACT TO COMMIT MORTGAGE FRAUD BY LYING CHEATING PLAINTIFF MARYANN CASTRO OUT OF HER HOMESTEAD DISABLED HOMESTEAD PLAINTIFF MARYANN CASTRO AND MANUEL CASTRO ARE SEEKING DAMAGES AND TO REMAIN IN THEIR HOME 1501 OLIVE SECURE THE TITLE ON THEIR HOME THAT WAS FALSELY WRONGFULLY FORECLOSED ON SEPT 1,2015. 7. IT IS NOT TO LATE TO FIX THE FRAUD AND FALSE FORECLOSURE THAT BSI ALSO KNOWN AS SN SERVICING COMMITED AGAINST PLAINTIFF MARYANN CASTRO AND MANUEL CASTRO A NOTICE OF PENDING ACTION KNOWN AS LIS PENDENS WILL BE FILED AGAINST THE TITTLE TO THE SUBJECT PROPERTY 1501 OLIVE AND PLAINTIFF MARYANN CASTRO HAS REQUESTED A TRIAL AGAINST SN SERVICING KNOWN AS BSI FINANCIAL FOR MORTGAGE FRAUD AND FALSE STATEMENT ALSO TO INCLUDE WRONGFUL FORECLOSURE AND FOR PLAINTIFF MARYANN CASTRO TO REMAIN IN HER HOME 1501 OLIVE UNTIL THE CASE IS SETTLED IN COURT WHO

*6 HAVE THE EVIDENCE OF FRAUD AND WRONGFUL FORECLOSURE THAT DID AND OCCURRED AND PLAINTIFF MARYANN CASTRO AND MANUEL CASTRO HAVE SUFFERED. 8. CIVIAL RICO ACT OF MORTGAGE FRAUD FALSE STATEMENT AND WRONGFUL FORECLOSURE BY SN SERVCING KNOWN AS BSI FINANCIAL AND PLAINTIFF MARYANN CASTRO AND MANUEL CASTRO HAVE SUFFERED THE EVIDENCE HAS BEEN ENTERED IN COURT.

PLAINTIFF MARYANN CASTRO PRAYS FOR JUSTICE MARYANN CASTRO PRO-SE P.O. BOX 495

PLEASANTON TEXAS 78064 PACATTITUDE2014@GMAIL.COM 830-406-0133

*7 CERTIFICATE OF SERVICE SENT CERTIFIED 9/14/15

*8

EXHIBIT A

*9 November 20, 2009

Manuel G Castro Jr 1501 Olive St Jourdanton TX 78026

Wells Fargo Home Mortgage MAC X7801-03K 3476 Stateview Boulevard Fort N.J. SC 29745

Dear Manuel G Castro Jr : RE: Loan Number 0150044675 Client 708 This letter will confirm our formal approval of a loan modification/ restructure of your mortgage loan. To facilitate this transaction, it was mutually agreed that a contribution of $ 1 , 491.66 would be required, which will be applied toward the accrued delinquency.

Please sign the enclosed loan modification agreement and return it, along with any payment (s) and/or contribution due as reflected in the terms of this letter. If a Truth in Lending Statement is enclosed with your modification agreement, please sign and return all items and contribution as disclosure of your interest rate being raised through this modification.

The terms of your modification/restructure are outlined below:

  1. Due date of first payment: 02 / 01 / 2010
  2. New principal and interest payment amount: $1,562.06
  3. Required escrow payment based on previous analysis: $169.74
  4. Estimated new net payment: $1,731.80
  5. Modified maturity date: 04 / 01 / 2036
  6. Interest rate: (The interest rate may change or adjust in accordance with the terms of your Note and Security Instrument.)
  7. All late charges, NSF fees, and other fees are the responsibility of the borrower.

This proposal is valid for five (5) days from the date of this letter. Therefore, it is imperative the modification agreement (s) be executed and returned in the enclosed, self-addressed, prepaid, express mail envelope. Please note, although approved, the normal servicing process will continue uninterrupted, unless advised otherwise.

Wells Fargo Home Mortgage is a division of Wells Fargo Bank, N.A.

*10

THIS LOAN MODIFICATION AGREEMENT made on November 20, 2009, by and between MANUEL G CASTRO JR and (the "Borrower(s)") and Wells Fargo Bank, N A (the "Lender")

W I T N E S S E T H

WHEREAS, Borrower has requested, and Lender has agreed, subject to the following terms and conditions, to a modification in the payment as follows:

NOW THEREFORE, in consideration of the covenants hereinafter set forth and of other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged by the parties, it is agreed as follows (notwithstanding anything to the contrary contained in the Note and Mortgage dated 03/07/2006):

  1. BALANCE. As of November 20, 2009, the amount payable under the Note and Mortgage (the "Unpaid Principal Balance") is U.S. $ 188 , 776.64 .
  2. EXTENSION. This agreement hereby modifies the following terms of the Security Instrument described herein above as follows: A. The current contractual due date has been extended from 11-01-07. The first modified contractual due date is due on 02/01/2010. B. The maturity date has been extended from 04-36 (month/year) to 04 / 01 / 2036 . C. The amount of interest to be capitalized will be U.S. $ 32 , 221.89 . The modified unpaid principal balance is U.S. $ 225 , 970.06 D. The borrower promises to pay the unpaid principal balance plus interest, to the order of the Lender. Interest will be charged on the unpaid principal balance of U.S. $ 225 , 970.06 . The borrower promises to make monthly payments of principal and interest of U.S. $ 1 , 562.06 , at a fixed yearly rate of 6.950 % , not including any escrow deposit, if applicable. If on the maturity date the borrower still owes amount under the Note and Security Instrument, as amended by this Agreement, borrower will pay these amounts in full on the maturity date.

LW175/LDB/Page 1

*11

Wells Fargo Home Mortgage

WACX7801-03K 3476 Stateview Boulevard Fort Mill, SC 29715

Page 2 Loan Number 708 / 0150044675 Please note that the final paragraph of the modification agreement entitled "CORRECTION AGREEMENT" gives us permission to correct any typographical errors in the modification. If you do not wish to consent to this, but still desire to enter into the modification, you may line through this paragraph. This and any adjustments must be initialed by you next to the change. Please note that it does not permit us to change any material terms such as interest rate, modification balance or monthly payment amount. If we can be of further assistance, please call us at (866) 234-8271, Monday through Friday, 8 AM to 8 PM, Central Time.

Sincerely, LaTonya A Patterson Borrower Counseling Services LW179/LDB Wells Fargo Bank, N A informs you that if your loan is currently delinquent or in default, as your loan servicer, we will be attempting to collect a debt, and any information obtained will be used for that purpose. However, if you have received a discharge, and the loan was not reaffirmed in the bankruptcy case, Wells Fargo Bank, N A will only exercise its right as against the property and is not attempting any act to collect the discharge debt from you personally.

*12 Wells Fargo Home Mortgage MAC X7801-03K 3476 Stateview Boulevard Fort MAIL SC 29715

Loan Modification Agreement Page 2 of 2 Loan 7080150044675 3. NOTE AND MORTGAGE. Nothing in this Agreement shall be understood or construed to be a satisfaction or release, in whole or in part of the Borrower's obligations under the Note or Mortgage. Further, except as otherwise specifically provided in this Agreement, the Note and Mortgage will remain unchanged, and Borrower and Lender will be bound by, and shall comply with, all of the terms and provisions thereof, as amended by this Agreement.

CORRECTION AGREEMENT. The undersigned borrower(s), for and in consideration of the approval, closing and funding of this Modification, hereby grants Wells Fargo Bank, N A, as lender, limited power of attorney to correct and/or initial all typographical or clerical errors discovered in the Modification Agreement required to be signed. In the event this limited power of attorney is exercised, the undersigned will be notified and receive a copy of the document executed or initialed on their behalf. This provision may not be used to modify the interest rate, modify the term, modify the outstanding principal balance or modify the undersigned's monthly principal and interest payments as modified by this agreement. Any of these specified changes must be executed directly by the undersigned. This limited power of attorney shall automatically terminate in 120 days from the closing date of the undersigned's Modification 70 C (Borrower Initial)

IN WITNESS WHEREOF, the parties hereto have executed this Agreement as the date first above written.

By signing this agreement I hereby consent to being contacted concerning this loan at any cellular or mobile telephone number I may have. This includes text messages, at no cost to me, and telephone calls including the use of automated dialing systems to contact my cellular or mobile telephone.

Wells Fargo Bank, N A, Officer/Date LW175/LDB/2

*13

When Recorded Mail To: FIRST AMERICAN TITLE P.O. BOX 27670

SANTA ANA, CA 92799-7670

LOAN MODIFICATION AGREEMENT - (Providing for Fixed Interest Rate)

This Loan Modification Agreement ("Agreement"), made this 20TH day of NOVEMBER, 2009 , between MANUEL G. CASTRO JR AND MARY CASTRO, EUSBAND AND WIFE ("Borrower") and WELLS FARGO BANK, N.A. ("Lender"), amends and supplements (1) the Mortgage, Deed of Trust or Security Deed (the "Security Instrument"), and Timely Payment Rewards Rider, if any, dated MARCH 7, 2086 and recorded in Instrument No. 2006-80487 , of the Official Records of (Name of Records) ATASCOSA COUNTY, TEXAS , and (2) the Note bearing the same date as, and (County and State, or other jurisdiction) secured by, the Security Instrument, which covers the real and personal property described in the Security Instrument and defined therein as the "Property", located at

1501 OLIVE STREET, JOURDANTON, TEXAS 78026 (Property Address)

*14

EXHIBIT B

*15

ADJUSTABLE RATE NOTE

THIS NOTE CONTAINE PROVISIONS ALLOWING FOR CHANGES IN MY INTEREST RATE AND MY MONTHLY PAYMENT. THIS NOTE LIMITS THE AMOUNT MY INTEREST RATE CAN CHANGE AT ANY ONE TIME AND THE MAXIMUM RATE I MUST PAY.

| MARCH 2, 2008 | PLEASAMTON | TEXAS | | :--: | :--: | :--: | | Date | City | State | | 1681 GLNE STREET, JOURDANTON, TX 78888 | | |

(Property Address)

1. BORROWER'S PROMISE TO PAY

In return for a loan that I have received, I promise to pay U.S. S......181,250.00. (this amount is called "principal"), plus interest, to the order of the Lender. The Lender is .WELLS FARGO BANK, N.A. I will make all payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder."

2. INTEREST

Interest will be charged on unpaid principal until the full amount of principal has been paid. I will pay interest at a yearly rate of ... 7,888 .... % . The interest rate I will pay will change in accordance with Section 4 of this Note. The interest rate required by this Section 2 and Section 4 of this Note is the rate I will pay both before and after any default described in Section 7(B) of this Note.

3. PAYMENTS

(A) Time and Place of Payments

I will pay principal and interest by making payments every month. I will make my monthly payments on the first day of each month beginning on ...MAT. 1, 2008. I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on ...APRIL.1,2036. I will owe amounts under this Note, I will pay those amounts in full on that date, which is called the "maturity date." I will make my monthly payments at WELLS FARGO BANK, N.A. P.O. BOX 17336, BALTIMORE MD 2129711338 or at a different place if required by the Note Holder. (B) Amount of My Initial Monthly Payments

Each of my initial monthly payments will be in the amount of U.S. S......1,394.67. This amount may change.

(C) Monthly Payment Changes

Changes in my monthly payment will reflect changes in the unpaid principal of my loan and in the interest rate that I must pay. The Note Holder will determine my new interest rate and the changed amount of my monthly payment in accordance with Section 4 of this Note.

4. INTEREST RATE AND MONTHLY PAYMENT CHANGES

(A) Change Datea

The interest rate I will pay may change on the first day of APRIL, 2008. and may change on that day every sixth month thereafter. Each date on which my interest rate could change is called a "Change Date."

(B) The Index

Beginning with the first Change Date, my interest rate will be based on an Index. The "Index" is the six month London Interbank Offered Rate ("LIBOR") which is the average of interbank offered rates for six-month U.S. dollar-denominated deposits in the London market, as published in The Wall Street Journal. The most recent Index figure available as of the first business day of the month immediately preceding the month in which the Change Date occurs is called the "Current Index." If the Index is no longer available, the Note Holder will choose a new index which is based upon comparable information. The Note Holder will give me notice of this choice. (C) Calculation of Changes

Before each Change Date, the Note Holder will calculate my new interest rate by adding ... % percentage points ( 1 , 5 , 000 … . % ) to the Current Index. The Note Holder will then round the result of this addition to the nearest one-eighth of one percentage point ( 0.125 % ) . Subject to the limits stated in Section 4(D) below, this rounded amount will be my new interest rate until the next Change Date. The Note Holder will then determine the amount of the monthly payment that would be sufficient to repay the unpaid principal that I am expected to owe at the Change Date in full on the maturity date at my new interest rate in substantially equal payments. The result of this calculation will be the new amount of my monthly payment.

*16

3 pgs
LISPEN
165237

FILED IN THE DISTRICT COURT

RECEIVED

SEP 142015 CLERK, U.S. IMMUNICT COURT WESTERN DISTRICT OF TEXAS BY

OF ATASCOSA COUNTY, TEXAS

RECORDING REQUESTED BY AND WHEN RECORDED MAIL TO: MARYANN CASTRO P.O. BOX 495 PLEASANTON TEXAS 78064

S

S

S

COMPETENT

DEPUWY CLERR

$

S Case no 5:15-CV-00715-DAE UNTIED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

NOTICE OF LIS PENDENCY OF ACTION

VS Defendant SN Servicing

*17

NOTICE OF LIS PENDENS AND NOTICE OF ACTION PENDING

PLEASE TAKE NOTICE THAT PLAINTIFF MARYANN CASTRO HAS FILED THE FOLLWING ACTION AGAINST DEFENDANTS SN SERVICING

  1. FILED ON OR ABOUT JULY 23, 2015 BY PLAINTIFF TO REDRESS INJURIES BEING SUFFERED AND TO BE SUFFERED AS A RESULT OF DEFENDANTS CONDUCT. DEFENDANTS HAVE ULAWFULLY TAKEN TITTLE TO PLAINTIFFS PROPERTY.
  2. PLAINTIFFS SEEKS TO PROTECT HIS/HER PROPERTY. PLAINTIFF IS OWNER OF PROPERTY KNOWN AS
  3. 1501 OLIVE JOURDANTON TEXAS 78026 AND LEGALLY DESCRIBED AS:
  4. BEING A 9.45 ACRE TRACT SITUATED IN THE J. POITEVENT SURVEY, ABSTRACT 1239, ATASCOSA COUNTY, TEXAS, AND BEING THAT SAME 9.45 ACRE TRACT AS CONVEYED BY THOMAS F. PERKS AND LOLA M. PERKS TO MANUEL G. CASTRO AND MARY A. CASTRO RECORDED IN VOLUME 152, PAGE 442, OFFICIAL PUBLIC RECORDS OF ATASCOSA COUNTY, TEXAS: SAID 9.45 ACRE TRACT SURVEYED BY JEFFREY B. BERGER, R.P.L.S. NO. 5558 ON AUGUST 19, 2005 AND BEING MORE PARTICULARLY DESCRIBED BY METES AND BOUNDS; more commonly known as, 1501 Olive St., Jourdanton, TX 78026 (hereinafter referred to as "the Property").

RECORDED AUGUST 19, 2005

FILED SEPT 14,2015

*18

ACKNOWLEDGEMENT

SUBSCRIBED AND SWORN TO BEFORE ME THIS NOTICE OF PENDENCY OF ACTION INSTRUMENT PREPARED BY MARYANN CASTRO ON THIS DAY OF September 14, 2015.

CERTIFICATE OF SERVICE 73 m PC SENT CERTIFIED SEPT 14, 2015

CONFORMED COPY OFFICIAL PUBLIC RECORDS

Case Details

Case Name: Mary Ann Castro v. Manuel Castro
Court Name: Court of Appeals of Texas
Date Published: Sep 15, 2015
Docket Number: 04-14-00785-CV
Court Abbreviation: Tex. App.
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