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NO
FORT BEND INDEPENDENT SCHOOL IN THE DISTRICT COURT
DISTRICT
VS. § IN AND FOR
NASHA HUNTER, DDS, PLLC D/B/A SWEET FORT BEND COUNTY, TEXAS
PEA SMILES
PLAINTIFFS ORIGINAL PETITION
TO THE HONORABLE JUDGE OF SAID COURT
Now come(s) the taxing districts set out below:
FIRST COLONY MUNICIPAL UTILITY DISTRICT # 10
FORT BEND COUNTY LEVEE IMPROVEMENT DISTRICT # 2
FORT BEND INDEPENDENT SCHOOL DISTRICT
on behalf of themselves and all taxing districts for whom they collect. Each is a political
subdivision of the State of Texas, each is legally constituted and authorized to impose and/or
collect ad valorem taxes, and each is hereinafter called “Plaintiff’, whether one or more, original
or intervenor, and for such cause of action would show the following:
1. The name(s) and address(es) of Defendants is/are:
NASHA HUNTER, DDS, PLLC D/B/A SWEET PEA SMILES BY
SERVING ITS PRESIDENT, NASHA T. FLETCHER
1703 GLADDEN WAY
SUGAR LAND, TX 77479-3179
Said Defendant(s) currently own(s) or claim(s) an interest in the property hereinafter described
and/or owned the hereinafter described property on the first day of January of each of the years
for which taxes are due and owing. Discovery is intended to be conducted under Level 2
pursuant to Rule 190 of the Texas Rules of Civil Procedure.
2. The taxes in the amounts and for the years shown below were legally imposed on each
separately described property and on the respective person named (if known) who owned the
property on January | of such years. Such taxes are delinquent and owing, along with penalties
and interest authorized by law and detailed below:
Property Code: 9960192120060907, 9960192120060 CPC: P329486, 99001329486
Description: Tract #1 - PERSONAL PROPERTY SUPPLIES, FURN, FIX, & EQUIP
LOCATED @ 15850 SOUTHWEST FWY #400 IN SUGAR LAND
Year Taxes Pen & Int Total
$2,963.39} $1,588.38} $4,55
$3,830.66} $1,363.72] $5,194.38}
{Total For: FORT BEND INDEPENDENT SCHOOL DISTRICT $9,746.15}
Year Taxes Pen & Int Total
$426.55] $228.63} $655.
$493.34) $175.62| $668.96)
{Total For: FIRST COLONY MUNICIPAL UTILITY DISTRICT # 10 $1,324.14)
Year Taxes Pen & Int Total
$249, $133.56] $382.75|
$420.79) $149.80] $570.59)
{Total For: FORT BEND COUNTY LEVEE IMPROVEMENT
$953.34)
DISTRICT #2
{rotal Due For Property $12,023.63]
[Research Fee: $125.00}
[Total for: May, 2019 $12,148.63]
(This amount does not include court costs which must be paid prior to dismissal).
The property is specifically described as follows:
Property Code: 9960192120060907, 9960192120060
TRACT #1: PERSONAL PROPERTY CONSISTING OF SUPPLIES,
FURNITURE, FIXTURES, AND EQUIPMENT, LOCATED IN FORT BEND
COUNTY, TEXAS.
In addition to the amounts stated above, Plaintiff(s) sue(s) for costs of court, foreclosure sale
expenses and research expenses for determining the name, identity and location of necessary
parties and in procuring necessary legal descriptions of the property, and other costs, all as
authorized by law. Further, Plaintiff(s) sue for all additional taxes which become delinquent on
such property prior to judgment, as well as any additional penalties and interest which accrue
prior to or after judgment, to the date of sale.
3 Plaintiff(s) would show that all conditions precedent to the right to levy said taxes were
performed as required by law; that all of said taxes were authorized by law; and that all things
required by law have been duly and legally performed by the proper officials.
4. Plaintiff(s) would further show that the Attorney signing this petition is legally authorized to
prosecute this suit on behalf of the taxing unit and Plaintiff(s) therefore request(s) attorney fees
as provided by law.
5. Each tract of the said above-described item(s) of personal property was, on January Ist of the
aforesaid years and at the time said taxes were imposed, located within the boundaries of each of
said taxing units and within the boundaries of FORT BEND COUNTY, TEXAS. Each taxing
unit asserts a lien on each separately described property listed above to secure the payment of all
taxes, penalties, interest and costs due.
6. Defendant(s) shall take notice of all pleas and interventions which may be filed by Plaintiff(s)
or any party intervening.
7. Plaintiff(s) would show that the party or parties who owned the property, described above, on
January | of the years indicated are indebted to Plaintiff taxing units for said taxes, penalties and
interest, and are liable Plaintiff(s) seek personal liability against such
for all costs herein.
owners, as well as foreclosure of the tax lien on each separately described property. As to all
other Defendants, Plaintiffs’ action is a proceeding in rem only, whereby Plaintiff(s) seek(s) to
foreclose the tax lien(s) on each separately described property listed in satisfaction of the taxes,
penalties, interest and all costs due or to become due herein.
WHEREFORE, Plaintiff(s) pray that Defendant(s) be cited to appear and answer herein and that
on final hearing recover the following:
Personal judgment against such Defendant(s), except those designated otherwise
above, who owned the property described herein on January Ist of the years indicated
above, for all taxes, penalties, interest, attorney fees, and costs that are due or will
become due;
B. Foreclosure of the tax liens, issuance of an order of sale and/or execution on the
property described above and payment of all taxes, penalties, interest, and costs that are
due or will become due and that are secured by such tax lien(s), which tax lien(s) are
first, prior and/or superior to any other interest in said property; and
C. Such other and further reliefto which Plaintiff(s) may be entitled.
Respectfully submitted,
PERDUE, BRANDON, FIELDER, COLLINS & MOTT, L.L.P.
ATTORNEYS AT LAW
1235 North Loop West
Suite 600
Houston, TX 77008
(713) 862-1860 FAX:(713) 862-1429
Email Address - PBFCM-Houston@pbfcm.com
Otilia R. Gonzales / Bar # 24010360
Yolanda M. Humphrey / Bar # 24009764
R. Gregory East / Bar # 24007138
File #: 190130
Acct#: 51400
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NO FORT BEND INDEPENDENT SCHOOL IN THE DISTRICT COURT DISTRICT VS. § IN AND FOR NASHA HUNTER, DDS, PLLC D/B/A SWEET FORT BEND COUNTY, TEXAS PEA SMILES PLAINTIFFS ORIGINAL PETITION TO THE HONORABLE JUDGE OF SAID COURT Now come(s) the taxing districts set out below: FIRST COLONY MUNICIPAL UTILITY DISTRICT # 10 FORT BEND COUNTY LEVEE IMPROVEMENT DISTRICT # 2 FORT BEND INDEPENDENT SCHOOL DISTRICT on behalf of themselves and all taxing districts for whom they collect. Each is a political subdivision of the State of Texas, each is legally constituted and authorized to impose and/or collect ad valorem taxes, and each is hereinafter called “Plaintiff’, whether one or more, original or intervenor, and for such cause of action would show the following: 1. The name(s) and address(es) of Defendants is/are: NASHA HUNTER, DDS, PLLC D/B/A SWEET PEA SMILES BY SERVING ITS PRESIDENT, NASHA T. FLETCHER 1703 GLADDEN WAY SUGAR LAND, TX 77479-3179 Said Defendant(s) currently own(s) or claim(s) an interest in the property hereinafter described and/or owned the hereinafter described property on the first day of January of each of the years for which taxes are due and owing. Discovery is intended to be conducted under Level 2 pursuant to Rule 190 of the Texas Rules of Civil Procedure. 2. The taxes in the amounts and for the years shown below were legally imposed on each separately described property and on the respective person named (if known) who owned the property on January | of such years. Such taxes are delinquent and owing, along with penalties and interest authorized by law and detailed below: Property Code: 9960192120060907, 9960192120060 CPC: P329486, 99001329486 Description: Tract #1 - PERSONAL PROPERTY SUPPLIES, FURN, FIX, & EQUIP LOCATED @ 15850 SOUTHWEST FWY #400 IN SUGAR LAND Year Taxes Pen & Int Total $2,963.39} $1,588.38} $4,55 $3,830.66} $1,363.72] $5,194.38} {Total For: FORT BEND INDEPENDENT SCHOOL DISTRICT $9,746.15} Year Taxes Pen & Int Total $426.55] $228.63} $655. $493.34) $175.62| $668.96) {Total For: FIRST COLONY MUNICIPAL UTILITY DISTRICT # 10 $1,324.14) Year Taxes Pen & Int Total $249, $133.56] $382.75| $420.79) $149.80] $570.59) {Total For: FORT BEND COUNTY LEVEE IMPROVEMENT $953.34) DISTRICT #2 {rotal Due For Property $12,023.63] [Research Fee: $125.00} [Total for: May, 2019 $12,148.63] (This amount does not include court costs which must be paid prior to dismissal). The property is specifically described as follows: Property Code: 9960192120060907, 9960192120060 TRACT #1: PERSONAL PROPERTY CONSISTING OF SUPPLIES, FURNITURE, FIXTURES, AND EQUIPMENT, LOCATED IN FORT BEND COUNTY, TEXAS. In addition to the amounts stated above, Plaintiff(s) sue(s) for costs of court, foreclosure sale expenses and research expenses for determining the name, identity and location of necessary parties and in procuring necessary legal descriptions of the property, and other costs, all as authorized by law. Further, Plaintiff(s) sue for all additional taxes which become delinquent on such property prior to judgment, as well as any additional penalties and interest which accrue prior to or after judgment, to the date of sale. 3 Plaintiff(s) would show that all conditions precedent to the right to levy said taxes were performed as required by law; that all of said taxes were authorized by law; and that all things required by law have been duly and legally performed by the proper officials. 4. Plaintiff(s) would further show that the Attorney signing this petition is legally authorized to prosecute this suit on behalf of the taxing unit and Plaintiff(s) therefore request(s) attorney fees as provided by law. 5. Each tract of the said above-described item(s) of personal property was, on January Ist of the aforesaid years and at the time said taxes were imposed, located within the boundaries of each of said taxing units and within the boundaries of FORT BEND COUNTY, TEXAS. Each taxing unit asserts a lien on each separately described property listed above to secure the payment of all taxes, penalties, interest and costs due. 6. Defendant(s) shall take notice of all pleas and interventions which may be filed by Plaintiff(s) or any party intervening. 7. Plaintiff(s) would show that the party or parties who owned the property, described above, on January | of the years indicated are indebted to Plaintiff taxing units for said taxes, penalties and interest, and are liable Plaintiff(s) seek personal liability against such for all costs herein. owners, as well as foreclosure of the tax lien on each separately described property. As to all other Defendants, Plaintiffs’ action is a proceeding in rem only, whereby Plaintiff(s) seek(s) to foreclose the tax lien(s) on each separately described property listed in satisfaction of the taxes, penalties, interest and all costs due or to become due herein. WHEREFORE, Plaintiff(s) pray that Defendant(s) be cited to appear and answer herein and that on final hearing recover the following: Personal judgment against such Defendant(s), except those designated otherwise above, who owned the property described herein on January Ist of the years indicated above, for all taxes, penalties, interest, attorney fees, and costs that are due or will become due; B. Foreclosure of the tax liens, issuance of an order of sale and/or execution on the property described above and payment of all taxes, penalties, interest, and costs that are due or will become due and that are secured by such tax lien(s), which tax lien(s) are first, prior and/or superior to any other interest in said property; and C. Such other and further reliefto which Plaintiff(s) may be entitled. Respectfully submitted, PERDUE, BRANDON, FIELDER, COLLINS & MOTT, L.L.P. ATTORNEYS AT LAW 1235 North Loop West Suite 600 Houston, TX 77008 (713) 862-1860 FAX:(713) 862-1429 Email Address - PBFCM-Houston@pbfcm.com Otilia R. Gonzales / Bar # 24010360 Yolanda M. Humphrey / Bar # 24009764 R. Gregory East / Bar # 24007138 File #: 190130 Acct#: 51400