T-0468-22-E
`SUIT NO. ___________________________
`
`
`Electronically Filed
`5/12/2022 1:38 PM
`Hidalgo County District Clerks
`Reviewed By: Marshall Schuller
`
`HIDALGO COUNTY, CITY OF DONNA,
`DONNA INDEPENDENT SCHOOL
`DISTRICT, HIDALGO COUNTY
`DRAINAGE DISTRICT # 01 AND SOUTH
`TEXAS COLLEGE, ET AL
`
`VS.
`
`DOMINGO TAMEZ, ET AL
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`IN THE DISTRICT COURT
`
`
`
`__________ JUDICIAL DISTRICT
`
`
`
`HIDALGO COUNTY, TEXAS
`
`
`
`
`
`ORIGINAL PETITION
`
`
`TO THE HONORABLE JUDGE OF SAID COURT:
`
`
`I.
`
`PLAINTIFF(S)
`
`
`
`This suit is brought for the recovery of delinquent ad valorem taxes under TEX. TAX CODE §
`33.41 by the following named Plaintiff(s), whether one or more, each of which is a taxing unit and is
`legally constituted and authorized to impose and collect taxes on property:
`
`HIDALGO COUNTY, CITY OF DONNA, SOUTH TEXAS INDEPENDENT SCHOOL
`DISTRICT, DONNA INDEPENDENT SCHOOL DISTRICT, HIDALGO COUNTY DRAINAGE
`DISTRICT # 01 AND SOUTH TEXAS COLLEGE
`
`
`The Plaintiff(s) intends discovery to be conducted under Level 2 of Rule 190, Texas Rules of
`Civil Procedure.
`
`
`DEFENDANT(S)
`
`
`
`The following are named as Defendant(s) in this suit, and they may be served with notice of these
`claims by service of citation at the address and in the manner shown as follows:
`
`Domingo Tamez, 313 S. 6th St., Donna, TX 78537;
`
`Charli Weiland Tamez, a/k/a Charli Lindsay Weiland a/k/a Charli Weiland, (Deceased)
`
`if living, and if any or all of the above named Defendant(s) be deceased, the unknown heirs of each or
`all of the said above named deceased persons; and the unknown owner or owners of the following
`described property; and the executors, administrators, guardians, legal representatives, devisees of the
`above named persons; and any and all other persons, including adverse claimants, owning or having any
`legal or equitable interest in or lien upon the below described property located in the county in which
`this suit is brought.
`
`
`The following taxing unit(s), whether one or more, is joined as a party herein as required by TEX.
`TAX CODE § 33.44(a) because it may have a claim and lien for delinquent taxes against all or part of the
`
`
`
`
`
`
`
`Suit Key No. 2588182
`
`

`

`
`
`Electronically Filed
`5/12/2022 1:38 PM
`Hidalgo County District Clerks
`Reviewed By: Marshall Schuller
`
`same property described below: HIDALGO COUNTY ROAD DISTRICT # 07. The foregoing named
`taxing unit(s), if any, is invited to add its claim by intervening herein.
`
`
`
`
`II.
`
`Claims for all taxes becoming delinquent on said property at any time subsequent to the filing of
`this suit, up to the day of judgment, including all penalties, interest, attorney’s fees, and costs on same,
`are incorporated in this suit, and Plaintiff(s) is entitled to recover the same, upon proper proof, without
`further citation or notice. Plaintiff(s) is further entitled to recover each penalty that is incurred and all
`interest that accrues on all delinquent taxes imposed on the property from the date of judgment to the
`date of sale.
`
`
`
`
`III.
`
`As to each separately described property shown below, there are delinquent taxes, penalties,
`interest, and costs justly due, owing and unpaid to Plaintiff(s) for the tax years and in the amounts as
`follows, if paid in May, 2022:
`
`
`PROPERTY AND AMOUNTS OWED
`
`Tax Year(s)
`2018
`2019
`2020
`
`Total Due
`Tax Amount Penalties and Interest
` $115.10
` $86.09 $201.19
` $160.72
` $98.04 $258.76
` $158.59
` $74.86 $233.45
`
`
`
` $434.41
`
` $258.99 $693.40
`
`Tax Year(s)
`2018
`2019
`2020
`
`Total Due
`Tax Amount Penalties and Interest
` $230.53
` $172.44 $402.97
` $220.50
` $134.51 $355.01
` $217.57
` $102.69 $320.26
`
`
`
` $668.60
`
` $409.64 $1,078.24
`
`
`ACCT. NO.G5046-00-000-0030-00; Lot Thirty (30), Golden Queen Mobile Home Subdivision, an
`Addition to the City of Donna, Hidalgo County, Texas, according to the map thereof recorded in
`Volume 39, Page 68, Map Records of Hidalgo County, Texas.
`
`HIDALGO COUNTY
`
`
`
`
`
`
`TOTALS:
`
`CITY OF DONNA
`
`
`
`
`
`
`TOTALS:
`
`DONNA INDEPENDENT SCHOOL DISTRICT
`
`
`
`
`
`
`TOTALS:
`
`Tax Year(s)
`2018
`2019
`2020
`
`Total Due
`Tax Amount Penalties and Interest
` $249.69
` $186.77 $436.46
` $342.89
` $209.17 $552.06
` $311.78
` $147.16 $458.94
`
`
`
` $904.36
`
` $543.10 $1,447.46
`
`
`
`
`
`
`
`Suit Key No. 2588182
`
`

`

`
`
`Electronically Filed
`5/12/2022 1:38 PM
`Hidalgo County District Clerks
`Reviewed By: Marshall Schuller
`
`Tax Year(s)
`2018
`2019
`2020
`
`Total Due
`Tax Amount Penalties and Interest
` $9.77
` $7.31 $17.08
` $13.75
` $8.39 $22.14
` $13.57
` $6.41 $19.98
`
`
`
` $37.09
`
` $22.11 $59.20
`
`Tax Year(s)
`2018
`2019
`2020
`
`Total Due
`Tax Amount Penalties and Interest
` $18.87
` $14.11 $32.98
` $29.38
` $17.92 $47.30
` $28.30
` $13.35 $41.65
`
`
`
` $76.55
`
` $45.38 $121.93
`
`SOUTH TEXAS INDEPENDENT SCHOOL DISTRICT
`
`
`
`
`
`
`TOTALS:
`
`HIDALGO COUNTY DRAINAGE DISTRICT # 01
`
`
`
`
`
`
`TOTALS:
`
`SOUTH TEXAS COLLEGE
`
`
`
`
`
`
`TOTALS:
`
`TOTAL DUE:
`
`
`Tax Year(s)
`2018
`2019
`2020
`
`Total Due
`Tax Amount Penalties and Interest
` $35.32
` $26.42 $61.74
` $48.44
` $29.55 $77.99
` $47.38
` $22.37 $69.75
`
`
`
`
`
` $131.14
`
`
`
` $78.34 $209.48
`
` $3,609.71
`
`The total aggregate amount of taxes, penalties, interest, and attorney’s fees (if any) for which
`Plaintiff(s) sues is $3,609.71, subject to additional taxes, penalties, interest, and attorney’s fees that
`accrue subsequent to the filing of this petition.
`
`
`
`
`IV.
`
`All of the taxes were authorized by law and legally imposed in the county in which this suit is
`brought. The taxes were imposed in the amount(s) stated above on each separately described property
`for each year specified and on each person named, if known, who owned the property on January 1 of
`the year for which the tax was imposed. Plaintiff(s) now has and asserts a lien on each tract of real
`property and each item of personal property described herein to secure the payment of all taxes, penalties,
`interest and costs due. Pursuant to Rule 54 of the Texas Rules of Civil Procedure, Plaintiff(s)
`affirmatively avers that all things required by law to be done have been done properly by the appropriate
`officials and all conditions precedent have been met.
`
`
`
`
`V.
`
`All of the property described above was, at the time the taxes were assessed, located within the
`territorial boundaries of each taxing unit in whose behalf this suit is brought. All Defendants named in
`this suit either owned the property that is the subject of this suit on January 1 of the year in which taxes
`
`
`
`
`
`
`
`Suit Key No. 2588182
`
`

`

`
`
`Electronically Filed
`5/12/2022 1:38 PM
`Hidalgo County District Clerks
`Reviewed By: Marshall Schuller
`
`were imposed on said property, or owned or claimed an interest in or lien upon said property at the time
`of the filing of this suit. The value of any personal property that may be described above, and against
`which the tax lien is sought to be enforced, is in excess of FIVE HUNDRED AND NO/100 DOLLARS
`($500.00).
`
`
`
`
`VI.
`
`The Law Firm represented by the attorney whose name is signed hereto is legally authorized and
`empowered to institute and prosecute this action on behalf of Plaintiff(s). Plaintiff(s) should recover
`attorney's fees as provided by law for the prosecution of this case, and such attorney's fees should be
`taxed as costs.
`
`
`
`
`VII.
`
`Plaintiff(s) may have incurred certain expenses in the form of abstractor’s costs in procuring data
`and information as to the name, identity and location of necessary parties, and in procuring necessary
`legal descriptions of the property that is the subject of this suit. Said expenses, if incurred, are reasonable
`and are in the following amount: $225.00. The abstractor's costs, if any be shown, should be taxed as
`costs herein.
`
`
`
`
`PRAYER
`
`WHEREFORE, PREMISES CONSIDERED, Plaintiff(s) requests that citation be issued and
`served upon each Defendant named herein, commanding them to appear and answer herein in the time
`and manner required by law. Plaintiff(s) further prays, upon final hearing in this cause, for foreclosure
`of its liens against the above-described property securing the total amount of all delinquent taxes,
`penalties and interest, including taxes, penalties and interest becoming delinquent during the pendency
`of this suit, costs of court, attorney's fees, abstract fees, and expenses of foreclosure sale. Plaintiff(s)
`further prays for personal judgment against Defendant(s) who owned the property on January 1 of the
`year for which the taxes were imposed for all taxes, penalties, interest, and costs that are due or will
`become due on the property, together with attorney's fees and abstractor's fees. Plaintiff(s) further prays
`for: (1) the appropriate order of sale requiring the foreclosed property to be sold, free and clear of any
`right, title or interest owned or held by any of the named Defendants, at public auction in the manner
`prescribed by law, and (2) writs of execution, directing the sheriffs and constables for the State
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Suit Key No. 2588182
`
`

`

`
`
`Electronically Filed
`5/12/2022 1:38 PM
`Hidalgo County District Clerks
`Reviewed By: Marshall Schuller
`
`of Texas, to search out, seize, and sell sufficient property of the Defendant(s) against whom personal
`judgment may be awarded to satisfy the lawful judgment sought herein. Finally, Plaintiff(s) prays for
`such other and further relief, at law or in equity, to which it may show itself justly entitled.
`
`
`Respectfully submitted,
`
`LINEBARGER GOGGAN
`BLAIR & SAMPSON, LLP
`1512 S. LONE STAR WAY
`EDINBURG, TX 78539
`(956) 383-4500
`(956) 383-7820 - FAX
`
`
`
`Lucy G. Canales
`State Bar No. 08123075
`Michael G. Cano
`State Bar No. 24047724
`Kelly Rivera Salazar
`State Bar No. 24041785
`Jaime E. Gonzalez
`State Bar No. 24036654
`Edinburg.Litigation@lgbs.com
`Attorney for Plaintiffs
`
`
`
`
`
`
`
`
`Suit Key No. 2588182
`
`

`

`Automated Certificate of eService
`This automated certificate of service was created by the efiling system.
`The filer served this document via email generated by the efiling system
`on the date and to the persons listed below. The rules governing
`certificates of service have not changed. Filers must still provide a
`certificate of service that complies with all applicable rules.
`Diana Salinas on behalf of Michael Cano
`Bar No. 24047724
`diana.salinas@lgbs.com
`Envelope ID: 64449435
`Status as of 5/12/2022 2:09 PM CST
`
`Case Contacts
`
`Name
`Michael Cano
`
`BarNumber Email
`michael.cano@lgbs.com
`
`TimestampSubmitted
`5/12/2022 1:38:38 PM
`
`Status
`SENT
`
`