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Filed: 5/9/2016 12:55:35 PM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 10526268
By: Shailja Dixit
5/9/2016 12:57:37 PM
NO. 15CV0344
ALAN CRAMER, § IN THE DISTRICT COURT OF
Plaintiff, §
v. §
§ GALVESTON COUNTY, TEXAS
§
GEORGE WOOD, § 122nd JUDICIAL DISTRICT
Defendant
STIPULATIONS OF FACT
TO THE HONORABLE JUDGE OF SAID COURT:
Plaintiff, Alan Cramer, and Defendant, George Wood, file and agree to these
Stipulations of Fact and in support thereof, respectfully show that the parties agree that there
is no genuine issue with respect to the following facts:
1. On September 2, 2014, a Notice of Federal Tax Lien against Defendant George Wood,
claiming an unpaid balance of assessments for taxes for the years 2005, 2006, 2009 and
2010, in the cumulative amount of $455,351.30, was recorded in the Official Public Records
of Galveston County Texas, under instrument number 2014049694 (PX-1).
2. On September 29, 2014, a Notice of Federal Tax Lien against Defendant George Wood,
claiming an unpaid balance of assessments for taxes for the years 2005, 2006, 2009 and
2010, in the cumulative amount of $455,423.30, was recorded in the Official Public Records
of Galveston County Texas, under instrument number 2014055293 (PX-2).
3. On December 14, 2014, the parties made an agreement, entitled “Rule 11 Agreement
George Wood and Alan Cramer” by which the parties agreed to compromise and settle a
partnership accounting dispute, and to sever the parties’ relationship as co-owners of a
number of parcels of real estate (PX-3).
3. On December 15, 2014, Defendant George Wood executed and delivered his special
warranty deed to Plaintiff, of and to the Defendant’s undivided one- fourth interest in Lot
Nineteen (19), in Block "J" of JAMAICA BEACH, Section Eight (8), a Subdivision in
Galveston County, Texas, according to the map or plat thereof recorded in Volume 254-A,
Page 87, of the Map Records of Galveston County, Texas (PX-4).
4. Plaintiff Alan Cramer made the payment and executed the conveyances to Defendant
George Wood contemplated by the “Rule 11 Agreement George Wood and Alan Cramer.”
5. On January 21, 2015, an attorney for Plaintiff, Alan Cramer, wrote the attorney for
Defendant, George Wood, with reference to the Notice of Federal Tax Lien (PX-5).
6. This lawsuit was filed on April 8, 2015.
7. On August 25, 2015, certificates of release of the federal tax liens were filed in the Real
Property records of Galveston County, Texas, effecting a release of the Notice of Federal Tax
Lien (PX-6).
Plaintiff and Defendant request that the facts recited above be deemed established,
and the referenced exhibits admitted, without need to present further evidence in support
thereof, in connection with the trial of this cause. This filing does not constitute an “agreed
statement of facts,” constituting “the record of the cause,” as provided by Tex. R. Civ. P. 263.
Respectfully submitted,
/s/Thomas W. McQuage
Post Office Box 16894
Galveston, Texas 77552-6894
(409) 762-1104
(409) 762-4005 (FAX)
State Bar No. 13849400
mcquage@swbell.net
ATTORNEY FOR PLAINTIFF
/s/ Mark W. Stevens
PO Box 8118
Galveston, TX 77553
(409) 765-6306
(409) 765-6469 (FAX)
State Bar No. 19184300
markwandstev@sbcglobal.net
ATTORNEY FOR DEFENDANT
It is so ordered.
JUDGE PRESIDING
Preview
Filed: 5/9/2016 12:55:35 PM JOHN D. KINARD - District Clerk Galveston County, Texas Envelope No. 10526268 By: Shailja Dixit 5/9/2016 12:57:37 PM NO. 15CV0344 ALAN CRAMER, § IN THE DISTRICT COURT OF Plaintiff, § v. § § GALVESTON COUNTY, TEXAS § GEORGE WOOD, § 122nd JUDICIAL DISTRICT Defendant STIPULATIONS OF FACT TO THE HONORABLE JUDGE OF SAID COURT: Plaintiff, Alan Cramer, and Defendant, George Wood, file and agree to these Stipulations of Fact and in support thereof, respectfully show that the parties agree that there is no genuine issue with respect to the following facts: 1. On September 2, 2014, a Notice of Federal Tax Lien against Defendant George Wood, claiming an unpaid balance of assessments for taxes for the years 2005, 2006, 2009 and 2010, in the cumulative amount of $455,351.30, was recorded in the Official Public Records of Galveston County Texas, under instrument number 2014049694 (PX-1). 2. On September 29, 2014, a Notice of Federal Tax Lien against Defendant George Wood, claiming an unpaid balance of assessments for taxes for the years 2005, 2006, 2009 and 2010, in the cumulative amount of $455,423.30, was recorded in the Official Public Records of Galveston County Texas, under instrument number 2014055293 (PX-2). 3. On December 14, 2014, the parties made an agreement, entitled “Rule 11 Agreement George Wood and Alan Cramer” by which the parties agreed to compromise and settle a partnership accounting dispute, and to sever the parties’ relationship as co-owners of a number of parcels of real estate (PX-3). 3. On December 15, 2014, Defendant George Wood executed and delivered his special warranty deed to Plaintiff, of and to the Defendant’s undivided one- fourth interest in Lot Nineteen (19), in Block "J" of JAMAICA BEACH, Section Eight (8), a Subdivision in Galveston County, Texas, according to the map or plat thereof recorded in Volume 254-A, Page 87, of the Map Records of Galveston County, Texas (PX-4). 4. Plaintiff Alan Cramer made the payment and executed the conveyances to Defendant George Wood contemplated by the “Rule 11 Agreement George Wood and Alan Cramer.” 5. On January 21, 2015, an attorney for Plaintiff, Alan Cramer, wrote the attorney for Defendant, George Wood, with reference to the Notice of Federal Tax Lien (PX-5). 6. This lawsuit was filed on April 8, 2015. 7. On August 25, 2015, certificates of release of the federal tax liens were filed in the Real Property records of Galveston County, Texas, effecting a release of the Notice of Federal Tax Lien (PX-6). Plaintiff and Defendant request that the facts recited above be deemed established, and the referenced exhibits admitted, without need to present further evidence in support thereof, in connection with the trial of this cause. This filing does not constitute an “agreed statement of facts,” constituting “the record of the cause,” as provided by Tex. R. Civ. P. 263. Respectfully submitted, /s/Thomas W. McQuage Post Office Box 16894 Galveston, Texas 77552-6894 (409) 762-1104 (409) 762-4005 (FAX) State Bar No. 13849400 mcquage@swbell.net ATTORNEY FOR PLAINTIFF /s/ Mark W. Stevens PO Box 8118 Galveston, TX 77553 (409) 765-6306 (409) 765-6469 (FAX) State Bar No. 19184300 markwandstev@sbcglobal.net ATTORNEY FOR DEFENDANT It is so ordered. JUDGE PRESIDING