On May 24, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Hidalgo County, Texas,
and
De Leon, Linda M,
Garcia, Abimael,
Garcia, Dahlia,
Garcia, Federico,
Garcia, Irma P.,
Garcia, Samuel,
The United States Of America Department Of The Treasury-Internal Revenue Service,
for Condemnation (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Submitted
1/23/2024 4:24 PM
Hidalgo County Clerk
Accepted by: Brianda Lynette Hernandez
P 10 Mile 6
ROW CJS 0921-02-355
CAUSE NO. CCD-0728-A
HIDALGO COUNTY, TEXAS § CONDEMNATION PROCEEDINGS
Plaintiff § FILED
§
v. §
§
PROPERTY OWNER: §
THE KNOWN AND UNKNOWN HEIRS §
OF FEDERICO GARCIA AND § IN COUNTY COURT AT LAW NO. 1
IRMA GARCIA §
§
LIENHOLDER: §
THE UNITED STATES OF AMERICA §
DEPARTMENT OF THE TREASURY §
INTERNAL REVENUE SERVICE §
Defendants § OF HIDALGO COUNTY, TEXAS
______________________________________________________________________________
PLAINTIFFS’ MOTION FOR ENTRY OF FINAL JUDGMENT
TO THE HONORABLE JUDGE OF THIS COURT:
Plaintiff HIDALGO COUNTY, TEXAS file this Motion for Entry of Final Judgment and would
respectfully show the Court as follows:
1. This condemnation proceeding was filed on May 24, 2023, and Amended on
September 13, 2023. The special commissioners’ hearing was held on October 27, 2023, and the
special commissioners entered an award. The special commissioners’ award was filed with the
Court on October 27, 2023.
2. Plaintiffs request that the Court set this matter for final hearing and sign and enter
Judgment in Absence of Objections.
Respectfully submitted,
PEREZ LAW FIRM, PLLC
208 Lindberg Ave.
McAllen, Texas 78501
Telephone: (956) 782-2700
Facsimile: (956) 782-2703
Email: erick@perezlegal.com
Electronically Submitted
1/23/2024 4:24 PM
Hidalgo County Clerk
Accepted by: Brianda Lynette Hernandez
BY: /s/ Ricardo Perez
Ricardo Perez
State Bar ID #24048723
Erick G. Holguin
State Bar ID #24097844
ATTORNEYS FOR PLAINTIFFS
CERTIFICATE OF SERVICE
This is to certify that on the 24TH day of January , 2024, a true and correct copy of the
foregoing “Plaintiff’s Motion for Entry of Final Judgment” has been e-filed. Based on the records
currently on file, the Clerk of Court will transmit a “Notice of Electronic Filing” to all registered
counsel of record. All other parties were served via certified mail, return receipt requested, first
class mail and/or fax as follows:
VIA-Email: catina.perry@usdoj.gov
Catina Haynes Perry
Assistant United States Attorney
1000 Louisiana, Suite 2300
Houston, Texas 77002
Attorney for Defendant Lien Holder
The United States of America, Dept. of the Treasury
VIA-Email:pete@pd4law.com
Pete Diaz, Attorney-Ad-Litem
VIA: CMRRR 7021 2720 0003 1801 3900 VIA: CMRRR 7021 2720 0003 1801 3917
Samuel Garcia Linda M. De Leon
½ Lot Imperial Dr. 108 S. Railroad
La Blanca, Texas 78553 Edcouch, Texas 78538
as heir of Federico and Irma Garcia as heir of Federico and Irma Garcia
VIA: CMRRR 7021 2720 0003 1801 3924 VIA: CMRRR 7021 2720 0003 1801 3931
Abimael Garcia Dahlia Garcia
118 S. Railroad 100 Juarez Street
Edcouch, Texas 78538 Elsa, Texas 78543
as heir of Federico and Irma Garcia as heir of Federico and Irma Garcia
BY: /s/ Erick G. Holgui
Erick G. Holguin
Document Filed Date
January 23, 2024
Case Filing Date
May 24, 2023
Category
Condemnation (OCA)
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Electronically Submitted 1/23/2024 4:24 PM Hidalgo County Clerk Accepted by: Brianda Lynette Hernandez P 10 Mile 6 ROW CJS 0921-02-355 CAUSE NO. CCD-0728-A HIDALGO COUNTY, TEXAS § CONDEMNATION PROCEEDINGS Plaintiff § FILED § v. § § PROPERTY OWNER: § THE KNOWN AND UNKNOWN HEIRS § OF FEDERICO GARCIA AND § IN COUNTY COURT AT LAW NO. 1 IRMA GARCIA § § LIENHOLDER: § THE UNITED STATES OF AMERICA § DEPARTMENT OF THE TREASURY § INTERNAL REVENUE SERVICE § Defendants § OF HIDALGO COUNTY, TEXAS ______________________________________________________________________________ PLAINTIFFS’ MOTION FOR ENTRY OF FINAL JUDGMENT TO THE HONORABLE JUDGE OF THIS COURT: Plaintiff HIDALGO COUNTY, TEXAS file this Motion for Entry of Final Judgment and would respectfully show the Court as follows: 1. This condemnation proceeding was filed on May 24, 2023, and Amended on September 13, 2023. The special commissioners’ hearing was held on October 27, 2023, and the special commissioners entered an award. The special commissioners’ award was filed with the Court on October 27, 2023. 2. Plaintiffs request that the Court set this matter for final hearing and sign and enter Judgment in Absence of Objections. Respectfully submitted, PEREZ LAW FIRM, PLLC 208 Lindberg Ave. McAllen, Texas 78501 Telephone: (956) 782-2700 Facsimile: (956) 782-2703 Email: erick@perezlegal.com Electronically Submitted 1/23/2024 4:24 PM Hidalgo County Clerk Accepted by: Brianda Lynette Hernandez BY: /s/ Ricardo Perez Ricardo Perez State Bar ID #24048723 Erick G. Holguin State Bar ID #24097844 ATTORNEYS FOR PLAINTIFFS CERTIFICATE OF SERVICE This is to certify that on the 24TH day of January , 2024, a true and correct copy of the foregoing “Plaintiff’s Motion for Entry of Final Judgment” has been e-filed. Based on the records currently on file, the Clerk of Court will transmit a “Notice of Electronic Filing” to all registered counsel of record. All other parties were served via certified mail, return receipt requested, first class mail and/or fax as follows: VIA-Email: catina.perry@usdoj.gov Catina Haynes Perry Assistant United States Attorney 1000 Louisiana, Suite 2300 Houston, Texas 77002 Attorney for Defendant Lien Holder The United States of America, Dept. of the Treasury VIA-Email:pete@pd4law.com Pete Diaz, Attorney-Ad-Litem VIA: CMRRR 7021 2720 0003 1801 3900 VIA: CMRRR 7021 2720 0003 1801 3917 Samuel Garcia Linda M. De Leon ½ Lot Imperial Dr. 108 S. Railroad La Blanca, Texas 78553 Edcouch, Texas 78538 as heir of Federico and Irma Garcia as heir of Federico and Irma Garcia VIA: CMRRR 7021 2720 0003 1801 3924 VIA: CMRRR 7021 2720 0003 1801 3931 Abimael Garcia Dahlia Garcia 118 S. Railroad 100 Juarez Street Edcouch, Texas 78538 Elsa, Texas 78543 as heir of Federico and Irma Garcia as heir of Federico and Irma Garcia BY: /s/ Erick G. Holgui Erick G. Holguin