On October 17, 2023 a
Complaint,Petition
was filed
involving a dispute between
College Of The Mainland,
Galveston County,
San Leon Municipal Utility District,
and
Hooks Carter, Bobbie D.,
for Tax Delinquency
in the District Court of Galveston County.
Preview
Filed: 11/7/2023 2:47 PM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 81394753
By: Shailja Dixit
11/7/2023 3:17 PM
NO. 23TX0666
GALVESTON COUNTY, ET AL § IN THE 122ND DISTRICT COURT
§
VS. § IN AND FOR
§
BOBBIE D. HOOKS CARTER § GALVESTON COUNTY, TEXAS
INTERVENING PLAINTIFFS ORIGINAL PETITION
TO THE HONORABLE JUDGE OF SAID COURT
Now come(s) the taxing districts set out below:
DICKINSON 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:
BOBBIE D. HOOKS CARTER
248 13TH ST
SAN LEON, TX 77539
and any and all Defendants that are set out in Plaintiffs Petition are hereby incorporated by
reference and made a part hereof for all purposes.
Said Defendant(s) currently own or claim 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 1 of such years. Such taxes are delinquent and owing, along with penalties
and interest authorized by law and detailed below:
Property Code: 624000070039000 CPC: 148714
Description: Tract #1 - ABST 10 A EDWARDS LOTS 39-40 BLK 7 SAN LEON
Year Taxes Pen & Int Total
2020 $392.94 $295.49 $688.43
2021 $267.66 $162.73 $430.39
2022 $496.90 $230.56 $727.46
DICKINSON INDEPENDENT SCHOOL DISTRICT $1,846.28
(This amount does not include court costs which must be paid prior to dismissal.)
The property is specifically described as follows:
Property Code: 624000070039000
TRACT #1: LOTS THIRTY-NINE (39) AND FORTY (40), BLOCK SEVEN
(7), SAN LEON TOWNSITE, GALVESTON 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 real estate and/or item of personal property was, on
January 1st 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 GALVESTON 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 1 of the years indicated are indebted to Plaintiff taxing units for said taxes, penalties and
interest, and are liable for all costs herein. Plaintiff(s) seek personal liability against such
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.
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.
Emely Flores on behalf of Yolanda Humphrey
Bar No. 24009764
eflores@pbfcm.com
Envelope ID: 81394753
Filing Code Description: Counter Claim/Cross
Action/Interpleader/Intervention/Third Party
Filing Description: INTERVENING PLAINTIFFS ORIGINAL PETITION
Status as of 11/7/2023 3:18 PM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
MARK EDMUNDCIAVAGLIA mark.ciavaglia@lgbs.com 11/7/2023 2:47:04 PM SENT
Document Filed Date
November 07, 2023
Case Filing Date
October 17, 2023
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Filed: 11/7/2023 2:47 PM JOHN D. KINARD - District Clerk Galveston County, Texas Envelope No. 81394753 By: Shailja Dixit 11/7/2023 3:17 PM NO. 23TX0666 GALVESTON COUNTY, ET AL § IN THE 122ND DISTRICT COURT § VS. § IN AND FOR § BOBBIE D. HOOKS CARTER § GALVESTON COUNTY, TEXAS INTERVENING PLAINTIFFS ORIGINAL PETITION TO THE HONORABLE JUDGE OF SAID COURT Now come(s) the taxing districts set out below: DICKINSON 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: BOBBIE D. HOOKS CARTER 248 13TH ST SAN LEON, TX 77539 and any and all Defendants that are set out in Plaintiffs Petition are hereby incorporated by reference and made a part hereof for all purposes. Said Defendant(s) currently own or claim 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 1 of such years. Such taxes are delinquent and owing, along with penalties and interest authorized by law and detailed below: Property Code: 624000070039000 CPC: 148714 Description: Tract #1 - ABST 10 A EDWARDS LOTS 39-40 BLK 7 SAN LEON Year Taxes Pen & Int Total 2020 $392.94 $295.49 $688.43 2021 $267.66 $162.73 $430.39 2022 $496.90 $230.56 $727.46 DICKINSON INDEPENDENT SCHOOL DISTRICT $1,846.28 (This amount does not include court costs which must be paid prior to dismissal.) The property is specifically described as follows: Property Code: 624000070039000 TRACT #1: LOTS THIRTY-NINE (39) AND FORTY (40), BLOCK SEVEN (7), SAN LEON TOWNSITE, GALVESTON 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 real estate and/or item of personal property was, on January 1st 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 GALVESTON 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 1 of the years indicated are indebted to Plaintiff taxing units for said taxes, penalties and interest, and are liable for all costs herein. Plaintiff(s) seek personal liability against such 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. 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. Emely Flores on behalf of Yolanda Humphrey Bar No. 24009764 eflores@pbfcm.com Envelope ID: 81394753 Filing Code Description: Counter Claim/Cross Action/Interpleader/Intervention/Third Party Filing Description: INTERVENING PLAINTIFFS ORIGINAL PETITION Status as of 11/7/2023 3:18 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status MARK EDMUNDCIAVAGLIA mark.ciavaglia@lgbs.com 11/7/2023 2:47:04 PM SENT