~ CITATION IN DELINQUENT TAX SUIT
`
`CAUSENO.25TX0144
`
`THE STATE OF TEXAS
`
`. 12316 23RD ST.
`
`TO: MARKK. WALKER
`SANTA FE, GALVESTON County, 7TX 77510
`- YOU HAVE BEENSUED. YOU MAY EMPLOY AN ATTORNEY. OFYOUOR YOUR
`ATTORNEY DO NOT FILE A WRITTEN ANSWER WITH THE CLERKWHOISSUED
`THIS CIFATION BY 10:00 A.M: ON THE, MONDAY NEXT. FOLLOWING THE
`_ EXPIRATIONOF20 DAYS AFTER YOU WERE SERVED THISCITATION AND/OR |
`oO ORIGINAL PETITION, ADEFAULT JUDGMENT MAYBE TAKEN AGAINST.YOU.7 - .
`~- IN ADDIFION TO FILING A WRITTEN ANSWERWITH THE:CLERK, YOU MAYBE |
`REQUIRED TO MAKE INITIAL DISCLOSURES TO THE OTHER PARTIES OF THIS _
`SUIT. THESE DISCLOSURES. GENERALLY MUST BE MADE NO LATERTHAN 30
`
`TEXASLAWHELP.ORG.|
`
`_
`
`DAYS AFTER YOU FILE YOUR ANSWER WITH THE CLERK. FIND OUT MORE AT
`GREETINGS: YOU ARE HEREBYCOMMANDEDtoappear and answer,asdescribed inthe
`paragraph above, before the 122ND DISTRICT COURT OF GALVESTON COUNTY, TEXASat
`the Courthousein Galveston, Texas to answer the Plaintiffs’ Original Petition: GALVESTON
`COUNTY WATER CONTROL AND IMPROVEMENT DISTRICT #8 and SANTA FE
`INDEPENDENT. SCHOOLDISTRICTfiled on the 19th day of February, 2025 against, MARK
`K. WALKER, RESOLUTION FINANCE, LLC,GRAND BANK FOR: SAVINGS, FSB, LVNV
`FUNDING,LLC, CITIBANK, N.A., Defendant(s), saidsuit being Cause no. 25TX0144 on the
`~ Court’s docket, the nature of which:‘demandiis a suit to collect delinquent ad valorem taxes on
`property hereinafter described.
`‘The amountoftaxes due Plaintiffexclusive ofinterest, penalties, and costs, is the sum of
`$4,489.74. The total amount owedasofthe date ofthis citation being issued (including penalty,
`interest,andCosts)4isas follows:
`.
`
`
`
` Total
`fe
`: Plaintiff
`
`Base Tax
`Pen& Int
`". SANTA FE INDEPENDENT. SCHOOL DISTRICT
`
`$3,328.38
`’
`|GALVESTON.COUNTY WATER CONTROL AND
`[IMPROVEMENTDISTRICT#8
`[Research Fee:
`Total Due ForFebruary 2025
`(This amountdoes:notnt
`include courtcosts which.mustbepaidpriorto dismissal).
`
`
`
`.
`
`- $4,500.07,
`
`
`25—TX -0144
`DecIRU
`
`‘Citation Returned Unexecutedia
`
`
`
`
`
`
`
`
`

`

`“
`
`The property is specifically:described as follows:
`Property Code: 830074700012097
`TRACT#1: PERSONAL PROPERTY CONSISTING OF A 1996 MOBILE HOME,
`SERIAL NUMBERTXFLT12A75523SB21, 14X66 TAN, LOCATED IN GALVESTON
`COUNTY, TEXAS.
`Property|Code:7470000001200
`TRACT #2:LOTS TWELVE (12) AND THIRTEEN(13), IN‘WEST-HO.SUBDIVISION,
`A SUBDIVISION OUT OF ALTA LOMA OUTLOT263, LOCATED IN GALVESTON:
`COUNTY, TEXAS, ACCORDINGTO THE MAP OR PLAT THEREOF RECORDED IN
`_ VOLUME 254, PAGE 83, LATER TRANSFERRED TOPLAT RECORD 14, MAP .
`- NUMBER41, OF THEMAP RECORDSIN THE OFFICE OF THE COUNTY CLERK .
`OF GALVESTON COUNTY, TEXAS
`:
`Said. suit cannot be.dismisseduntil the court costs ass well asthe claimof plaintiffs:atid any Ly
`intervenorhave beenpaid in full.
`-
`The nameofall taxing units which assess and collect taxeson said property not madea party to
`
`_.
`
`_
`
`said suit are:
`
`GALVESTON COUNTY, COLLEGE OF THE MAINLAND, GALVESTON COUNTY
`ROAD & FLOOD, CITY OF SANTA FE, GALVESTON COUNTY: EMERGENCY
`SERVICE #01, GALVESTON COUNTY DRAINAGE#1
`
`Plaintiff and all other taxing units who may set up their tax claims hereinseek recovery of
`delinquent.ad valorem taxes onthe-property hereinabove described, and in additionto.the taxes,
`all interest,penalties, and costs allowed by law thereon up to and including the day ofjudgment
`herein, and the establishmentand foreclosureof liens securing the payment of same, as provided
`by law.
`-
`
`_
`
`All parties to this suit, including Plaintiffs, Defendants, and Intervenor, shall take noticethat claims
`not only for taxes which were delinquent on-said property at the time this suit was filed, but all
`taxes which become delinquent thereon at anytime thereafter, up to the day ofjudgment, including
`“all ititerest, penalties and costs-allowedbylawthereon,may, upon request therefore, be recovered
`herein without further citation or notice to any parties herein, and all said parties shall takenotice
`of and plead and answerto all claims and pleadings now onfile and which mayhereafter befiled
`in this cause by all other patties hereto and by all of those taxing units above named, who may
`intervene hereinandsetFup‘their respective tax claims against said property.
`Ifthis citation is not‘served within 90 days after its issuance, it shall be returned unserved.
`The officer executingthis citation shall promptly serve thesameaccording to the requirements of
`law and mandates hereof and make due return as the law directs.
`
`
`
`

`

`7
`
`Ly.
`
`=
`
`Issued but notpreparedby District Clerk's Office and given under myhand & seal of
`office of said court of Galveston, GALVESTON COUNTY, TEXASon this the 20th day of
`February
`, 2025
`
` John D. Kinard
`
`JOHN D. KINARD - DISTRICT CLERK.
`600 59TH STREET
`-
`
`.
`
`PLAINTIFF’S/INTERVENORS’ ATTORNEY:
`PERDUE, BRANDON,FIELDER, COLLINS,
`‘& MOTT, L.L.P.
`1235.North Loop West
`Suite 600
`Houston, TX: 77008
`.
`(713) 862-1860 FAX:(713) 862-1429
`
` Acct#: 15771
`-File#: 250041
`
`
`
`

`

`ay
`
`a
`
`RETURN OF SERVICE
`CAUSE NO. 25TX0144
`IN THE122ND DISTRICT COURT
`SANTA FE INDEPENDENT SCHOOLDISTRICT, ET AL vs. MARK K. WALKER, ET AL
`County,
`“at
`~ o’clock ___-m., and executed in
`Cometo hand on
`Texas by delivering to each ofthe within namedparties in person, a true copy ofthe CITATIONwith the delivery endorsed
`thereon, together with the accompanying copy of the ORIGINAL PETITIONat the following times and places, to wit:
`
`MARK K. WALKER
`12316 23RD ST
`_
`SANTA FE, TX 77510
`
`:
`‘ LOCATION/ADDRESS SERVED:
`
`
`
`
`|
`
`
`
`
`
`
`
`andnot executed as to (Name)
`
`and the causeor failure to execute this process is for the following reason: _-
`
`
`The diligence used in finding said (Name) being:
`
`FEES:
`Serving CITATION and Copy
`Mileage:
`miles @ $
`Total
`
`permile
`
`$
`
`
`
`Officer
`County, TX
`
`Deputy/Authorized Person
`
`
`COMPLETE IF YOU ARE A PERSON OTHER THAN A SHERIFF, CONSTABLE, OR CLERK OF THE COURT. In
`accordance with rule 107: The officer or authorized person whoserves, or attempts to serve, a citation shall sign the retam. The
`signature is not required to be verified. If the return is signed by a person otherthan a sheriff, coristable, or the clerk of the court
`the return shall be signed underpenalty ofperjury and contain the following statement.
`
`
`"My name.is
`
`a , my'date ofbirth is
`= _
`”” (First? Middle, Last) TT Eg
`
`and my addressis
`
`oo
`Street, City, State, Zip Code, County
`
`
`‘DECLARE UNDER PENALTY OF PERJURY THAT THE
`- Executed in
`:
`County, State of
`
`.
`
`REGOING IS TRUE AND CORRECT."
`, on
`gery
`Declarant/Authorized Process Server
`
`ID# andexpiration ofcertification
`
`

`

`q |
`
`.
`
`“
`
`'
`
`os
`
`25-TX-0144
`ae
`NO..
`
`
`SAN “A FE INDEPENDENT SCHOOL
`DISTRICT, ET AL
`VS.
`
`.
`
`.
`
`"Filed: 2/19/2025 9:47 AM
`JOHN D. KINARD- District Clerk
`- Galveston County, Texas
`Envelope No. 97532132 ©
`By: Shailja Dixit
`2/19/2025 10:03 AM -~
`
`
`GalvestorCouryTokCOORTot Court
`
`DISTRICT.
`
`IN.AND FOR
`
`_MARKK. WALKER, BT AL
`
`GALVESTONCOUNTY, TEXAS_
`
`PLAINTIFF’S ORIGINALPETITION
`
`_. TO, THE HONORABLEJUDGEOF SAID COURT
`
`“Nowcoine(s)the taxingdistricts set outbelow:
`
`
`
`SANTA FE, TX 77510
`RESOLUTION FINANCE, LLC, (IN REM ONLY)
`BY SERVINGITS R
`IST REDAGENT, MATTT. LONGHOFER»
`
`4100.ALPHA ROAD, SUITE 670
`~ DALLAS, TX 75244
`GkLANDBANK-FORSAVINGS,PSB,ENIREMONLY): ne
`
`
`204 WESTOVER DR
`HATTIESBURG;MS 39402
`(SERVICE THROUGH THE SECRETARY OFSTATEOF TEXAS)
`LVNV FUNDING,LLC, (IN REMONLY)
`BY SERVINGITS REGISTERED AGENT, CSC-LAWYERS
`
`INCORPORATINGSERVICE COMPANY
`’ 241 E. 7THSTREETSUITE620
`AUSTIN, TX78701
`
`

`

`CITIBANK, NiAs,2 ON:REMONLY)
`
` XFA LLS, SD 57108
`(SERVICETHROUGHTHESECRETARYOF STATEOFTEXAS)
`The defendant(s) named above who donot. reside|in‘the State: of Texas may be served as
`provided by Section 17.091 of the Texas. Civil Practice & Remeédiés Code becatisé the
`defendant(s) own, have or¢laims an-interest or lien in property”inthe State.of Texas that is the
`‘subject. ofthis.suit and is a nonresident. Service may be.hadonthe defendant(s) by servingthe
`Secretary af State ofthe State of Texas, 1019 ‘Brazos, Rudder Building, Room 220,, Austin,
`"Travis County, ‘Texas. 78701, and copy forwarded. to the defendants" home or home office
`
`address as show. above.
`
`Said Defendant(s).currently own(s) or claim(s) an interest in. the property hereinafter: déseribed
`and/or ownedthe‘hereinafter. described property .onthefirst. day ofJanuaryofeachofthe years
`for whichtaxes are due and-owing. Discovery is intended to be conducted under Level 2
`pursuanttoRule 190ofthe Texas Rules ofCivil Procedure.
`2. The taxes inthe amountsand. for the years shownbelow were legally imposed oneach
`separately described ‘property and.on, the respective petson named. (ifknown) ‘who, ‘owned: the
`property onJanuary1 ofsuch years. Suchtaxes aredelinquent andowing;along withpenalties
`‘and interest authorizedbylaw anddetailed below:
`.
`
`Property Code! 830074700012097 CPC: 15680
`Description:‘Tract #1 - 1996 MHSERIAL# TXFIT12A75523SB21,LABEL #
`SADDLEBROOK14X66TANLINK
`
`
`
`
`
`
`
`__
`
`
`otal DuéFor Properties
`
`
`[IMPROVEMENTDISTRICT#8:
`
` Total For:‘GALVESTONCOUNTY WATER CONTROE AND
`
`
`__Propetty:Code:747000000012000- CPC:000194662
`Description:Tract #2 - ABST 149 PAGE110LOTS12&13 (12-1) WESTHO SUB :
`
`
`
`
`
`
`
`TotalFor:GALVESTON-COUNTY WATER CONTROL AND
`IMPROVEMENT.DISTRICT:#8
`
`
`
`

`

`
`
`
`
`
`
`ReRResearehFee:
`(This amountdoesnotincludecourtcosts which must.bépaidpriorto. dismissal).
`Thepropertyisspeciallydescribedas’follows: -
`PropertyCode! 830074700012097
`TRACT#1::PERSONAL PROPERTYCONSISTINGOFA199996 MOBILEHOME,
`
`
`| GALVESTONCOUNTY, TEXAS.
`Property Code: 747000000012000
`
`_
`
`COUNTY,uNTHR
`In additionto the amounts:“statedabove, Plaintifis)sue(s)for costsofcourt,‘foreclosuresale
`
`_, TRACT#2:LOTS TWELVE(1)ANDTHIRTEEN(13),INWESE-HO.
`
`4,Pisin)wouldfurthershowthatthe»Attomeysigningthispetitionislegally authorizedto bountai‘Bach,taxing unitasserts.a1 Tien on.each:Separatelydesotibed property listed above to
`
`0THE MAP OR
`
`
`requiredBylawhavebeenadulyaiidlegally:perfomiedbythefproperofficials...
`
` vaileftsaidfaxes'‘wereauthorizediby1 nid.thatalla
`
`secure the paymentofalltaxes, penalties, interestand costs due.
`- 6. Defendant(s) shalltakenoticeof:allpleas and interventionswhichmaybefiled byPlaintiff(s)
`or.anypartyintervening.
`
`

`

`
`
`
`‘WHEREFORE,Plaintifi(s)pr:
`‘on-final-hearingrecoverthe{
`
`
`C. Stichother:and-furilierrelieftowhichPlaintiffs)miay.beentitled,
`
`Respect‘submitted,
`
`
`
`BY
`“ —“fasoris= Balley8a 400790353.ameomoe
`.R:.GregoryEast / Bar# 24007138.
`“aland .M.Humphrey./Bar#24009764
`
`re
`"
`Bi
`:
`
`DamionJ.“Millington./Bar#24111178
`
`‘File #:'250041
`Acct#: 1ST.
`
`

`

`DUG I OC
`Cfretlh leHoe efuipe) Walley~osredOar ¢6fe)
`(Lecie we Fri. | Veerfit wel
`,
`
`NOT EXECUTED FOR REASON AFTER DUE SEARCH AND DILIGENT
`INQUIRY COULD NOT BE FOUNDIN GALVESTON COUNTY, TEXAS
`AND RETURNED ON THE 2A, DAY OF.
`MCAD, ATOR:
`6G AN.
`,
`rent Ae Ne
`
`
`.
`
`

`

`CAUSE NO.25TX0144
`THE STATE OFTEXAS
`
`TO: MARKK.WALKER
`12316 23RDST-
`
`INQUENT TAX SUIT
`
`e INOUEbehS
`
`
`EN
`
`-
`
`&
`
`
`
`SANTAFE, GALVESTON County, TX77510
`YOU HAVE BEEN SUED. YOU MAY EMPLOY AN ATTORNEY. IFYOU OR YOUR
`
`:
`
`ATTORNEYDO NOTFILE A WRITTEN ANSWER WITH THE CLERK WHO ISSUED
`_THIS CITATION BY 10:00 A.M. ON THE MONDAY NEXT FOLLOWING THE
`EXPIRATIONOF 20 DAYS AFTER. YOUWERE SERVED THIS CITATION AND/OR:
`.
`-ORIGINAL PETITION, A DEFAULT-JUDGMENT MAYBE TAKEN AGAINST YOU.-- -
`-.IN-ADDITION TO FILINGA WRITTEN ANSWER WITH THE CLERK, YOU MAYBE
`REQUIRED TO MAKE INITIAL DISCLOSURES TO THE OTHERPARTIESOF THIS
`SUIT. THESE DISCLOSURES.GENERALLY MUST BE MADE NO LATER THAN 30
`DAYS AFTER YOU FILE YOUR ANSWERWITH THE CLERK. FIND OUT MORE AT
`TEXASLAWHELP.ORG.
`
`GREETINGS:YOU.ARE HEREBYCOMMANDEDto. appear and answer,.as described in the
`paragraphabove,before the 122ND DISTRICT COURT OF GALVESTON COUNTY,TEXASat
`the Courthouse in Galveston, Texas to answer the Plaintiffs’ Original Petition: GALVESTON
`COUNTY WATER CONTROL AND IMPROVEMENT DISTRICT #8 and SANTA FE
`INDEPENDENT SCHOOLDISTRICTfiled on the 19th day of February, 2025 against, MARK
`- K, WALKER, RESOLUTIONFINANCE, LLC, GRAND BANK FOR SAVINGS, FSB, LVNV
`-.FUNDING, LLC, CITIBANK,N.A., Defendant(s), said suit being Cause no. 25TX0144 onthe ~
`
`Court’s docket, thenature of which“demandiis a suit to collect delinquentad valorem taxeson
`property hereinafter described..
`The amountoftaxes due Plaintiff, exclusive ofinterest, penalties, andcosts, is the sum of
`~ $4,489.74. The total amount owedas ofthe date ofthis citation being issued (eluding penalty,
`, interest,and costs) iis as.follows:..
`ae L:
`-
`:
`soe
`“
`om
`1
`
`
`|
`Base Tax
`Pen & Int
`Plaintiff
`
`
`
`SANTA FE INDEPENDENTSCHOOL DISTRICT
`$3,328.38
`$4,500.07,
`
`|GALVESTON COUNTY WATER CONTROL AND
`
`$1,582.78
`$1,161.36
`IMPROVEMENT DISTRICT #8
`Research Fee:
`;
`;
`
`$400.00,
`{Total Due ForFebruary, 2025
`_
`~ $6,482.85
`6This‘amount does notinclude court costs which must bepaidprior to dismissal.)
`.
`
`. rr
`
`Total
`
`
`
`
`
`SBO
`
`

`

`sy
`
`_ The property is specifically describedas follows:
`- Property: Code: 830074700012097-
`TRACT #1: PERSONAL PROPERTY CONSISTING OF A'1996 MOBILE HOME,..-
`SERIAL NUMBER TXFLT12A755238B21, 14X66 TAN, LOCATED IN GALVESTON ~
`COUNTY, TEXAS.
`
`ae
`
`|
`
`.
`
`:
`Property Code: 747000000012000
`TRACT #2: LOTS.TWELVE(12) AND THIRTEEN (13),.IN WEST-HO SUBDIVISION,
`_ A SUBDIVISION OUTOF ALTA LOMA OUTLOT263, LOCATEDINGALVESTON
`_. COUNTY, TEXAS, ACCORDINGTO THE MAP OR PLAT THEREOF:RECORDEDIN
`- VOLUME 254,PAGE 83;LATER TRANSFERRED TO PLAT.RECORD14, MAP
`NUMBER41, OF THE MAP RECORDS IN THE OFFICE OF THE COUNTY CLERK
`
`.
`. OF GALVESTON COUNTY, TEXAS .
`oSaid:suitcannotbe.dismissed until thecourt: costs.as well,aas“the claim of plaintiti and4 any”
`intervenorhavebeenpaid in fall.
`- The nameofall taxing units which assess and collect taxes on saidproperty not made a party to
`
`said suit are:
`GALVESTON COUNTY, COLLEGE OFTHE MAINLAND, GALVESTON COUNTY
`‘ROAD &FLOOD, CITY OF SANTA FE, GALVESTON COUNTY. EMERGENCY
`SERVICE#01, GALVESTON COUNTY DRAINAGE#1
`Plaintiff and. all other taxing:‘units who may set up their tax claims herein seek recovery of
`delinquent ad valorem taxes on the property hereinabove described, andin addition to the taxes,
`~~ all interest, penalties,.and costs allowed by law thereon upto and including the day ofjudgment
`herein, and the establishmentand foreclosure ofliens securing the paymentof same, as provided
`‘by law.
`Allparties to this suit, including Plaintiffs, Defendants, andIntervenor, shalltake notice that claims
`not onlyfor taxes which were delinquent on.said property at the time this suit was filed, butall
`-- taxes which becomedelinquentthereon at anytimethereafter, upto the day ofjudgment,including--
`~. all interest, penalties and-costsallowedby law:théreon,may,‘upon request therefore,be recovered
`herein without further citationor notice to any parties herein, and all said parties shall take notice
`of and plead and answerto all claims and pleadings now on file and which mayhereafter be filed
`in this cause byall other parties ‘hereto and by all of those taxingunits above named, who may
`
`intervene herein and set up their respective tax claims against said property.
`Ifthis citation is not setved within 90 daysafter its issuance, it shall be returned unserved.
`Lo
`FES The officer executing this.citation shall promptly serve the same accordingtothe requirements of
`7
`law: and mandateshereof’andmake due return as the law directs.
`
`

`

`‘
`
`wa
`
`Issued but not prepared by District Clerk's Office and given under my hand & seal of
`office of said court of Galveston, GALVESTON COUNTY, TEXASon this.the 20th day of
`February
`, 2025
`
`_John D. ‘Kinard.
`
`=
`JOHN D. KINARD - DISTRICT CLERK
`
`
`\
`
`600 59TH STREET
`
`
`
`PLAIN’TIFFS/INTERVENORS?‘ATTORNEY:
`PERDUE, BRANDON, FIELDER, COLLINS,
`& MOTT, L.L.P.
`1235 North Loop West
`Suite 600
`Houston, TX 77008
`(713) 862-1860 FAX:(713) 862-1429
`
`~ Acct#: 15771
`File#: 250041
`
`
`
`
`
`

`

`year
`
`RETURN OF SERVICE
`CAUSE NO. 25TX0144
`IN THE 122ND DISTRICT COURT
`oon
`SANTA FE INDEPENDENT SCHOOL DISTRICT,ET AL vs. MARK K. WALKER, ETAL
`County,
`- Cometo hand on ~_-
`at___-
`_o’clock
`_m., and executed in
`Texas by delivering to each ofthe within named parties.in person, a true copyyyof the CITATIONwith.the delivery endorsed
`thereon, togetherwith the accompanying copy of the ORIGINAL PETITIONatthe following timesand places,to wit:
`
`MARKK.WALKER
`“2 12316 23RD ST —
`SANTAFE, TX77510.
`LOCATION/ADDRESS SERVED:-
`PLACE, COURSE, AND DISTANCE FROM COURT HOUSE
`
`.
`
`2
`
`s:
`
`
`
`
`
`
`
`and not executed as to (Name)
`andthe cause or failure to execute this process is for the following reason:
`
`' The diligenceused in finding said (Name) being:
`
`/
`FEES:
`Serving CITATION and Copy
`Mileage:
`.
`miles @$
`Total
`~
`
`a
`
`;
`
`per mile
`
`
`
`
`
`$
`$
`
`:
`
`.
`
`:~, Officer
`County, TX
`
`Deputy/Authorized Person.
`COMPLETEIF YOU ARE A PERSON OTHERTHAN A SHERIFF CONSTABLE OR.CLERK OF THE COURT, In
`
`accordance with rule 107: The officer orauthorized person who serves, or attempts to serve,a citation shall sign the retum. The .
`signature is not required to be verified. If the return is signed by a person other than a sheriff, constable, or the clerk of the court
`the return shall be signedunder penalty ofperjury andcontain the foliowingstatement.
`"Mynameis a ae oo.
`: » mydateofbirthis
`eA rr ee
`This MidianFa =
`= Te OS
`
`oo.
`:
`Pinte ome og
`
`and my addressis
`
`Street, City, State, Zip Code, County
`
`1 DECLARE‘UNDER PENALTY OF PERJURY THAT THE FOREGOINGIS TRUE AND CORRECT."
`Executed in
`County, State of
`,on
`
`Declarant/Authorized Process Server
`
`
`
`ID# and expiration ofcertification
`
`