Mary Ann Castro v. Manuel Castro ( 2015 )

In the Fourth Court Of Appeals
Fourth Court Of Appeals District
San Antonio Texas Bexar County
Maryann Castro
v.
Manuel Castro
Re: Court Of Appeals Number: 04-14-00785-CV
Trial Court Case 2011 -CI-15957
To The Fourth Court of Justices In Appeals Court
STATEMENT FROM APPELLANT MARYANN CASTRO
MOTION TO ACCEPT FINAL CLOSING ARGUMENT AS TO WHY THE AGREEMENT FOR FINAL DIVORCE
SIGNED OCT 30,2013 SHOULD BE MODIFIED,AMENDED EVEN VOIDED AND REWRITTEN REOPENED TO
A JUST AND RIGHT DIVORCE DECREE DUE TO THE FOLLOWING MISREPRESENTATION,FRAUD THAT
OCCURED IN THE AGREEMENT FOR FINAL DIVORCE AGREEMENT SIGNED OCT 30,2013 THE FRAUD
WAS DISCOVERED AFTER THE DATE OF OCT 30,2013
OPINION (see copy of Agreement)
#1
This is an appeal from a final decree of divorce in which wife challenges the Agreement for Final
Divorce signed Oct30, 2013.Appellee Manuel Castro and Appellant Maryann Castro have been before
the Court. The Courts JUDGES never heard the actual facts in the Marriage of Manuel AND Maryann
Castro or even read documents showing the facts as to why the Agreement for Final Divorce should be
reopened, modified ,amended rewritten even voided, the ORIGINAL agreement was NEVER filed it
was tampered ,a copy was filed by Counsel Joseph Appelt who participated with his client Appellee
Manuel Castro in fraud, hiding martial asset, prejudice of Appellant Maryann Castro disability the
agreement has fraud bankruptcy, non-payment of mortgage, overvalued martial home, hiding martial
assets even Adultery, Cruelty. The Trial Court Judges erred in not voiding the Agreement for Final
Divorce(lf the Spouse seeking post judgement relief longstreet v longstreet, 57 ohio app.3d 55,566
N.E.2d 708 (1989) husband value home at 50,000 but sold it 14 months later for 79,000.(Salem V.
Salem, 610hio App. 3d 243,572,N.E. 2d 726 (1988)wife made conclusory allegations of nondisclosed
assets, citing a news paper article as her only basis for suspecting fraud) The time period for a motion
to reopen a judgement is tolled by the automatic stay imposed (A party seeking to reopen a
judgement has an obligation to act with reasonable diligence after learning relevant facts. E.G., In re
Gidlund,244 III..App.3d 675,614 N.E. 2d 315(1993)The law of reopening judgements should be
changed so that when one spouse commits deliberate and malicious fraud ,and the other spouse was
unable through due diligence to detect the fraud, there is no time limit ori the courts power to grant
effective relief.
BACKGROUND FACTS
Martial fraud on the Community estate, Appellant Maryann Castro is the innocent spouse in this
divorce fraud in the Communitywas committed by Appellee Manuel Castro and Counsel Joseph
Appelt by committing the following if there were no property then the lift stay does not need to be
filed there was 1501 Olive and the lift stay was not filed on Oct 30,2013 that isaviolation of family
and bankruptcy law Appellant Maryann Castro did not know Appellee Manuel Castro hadthe subject
property 1501 Olive in active bankruptcy and was not making the home mortgage payments.
A) APPELLEE MANUEL CASTRO FILED BANKRUPTCY WITHOUT NOTIFYING THE COURT OR
APPROVAL OF THE COURT AND DID NOT NOTIFY APPELLANT MARYANN CASTRO
THE BANKRUPTCY APPELLEE MANUEL CASTRO FILED WAS ACTIVE ON OCT 30,2013 AND STAY
LIFT NOT FILED OR APPROVED BY THE BANKRUPTCY COURT IN ORDER TO PROCEED IN THE
DIVORCE APPELLEE MANUEL CASTRO WAS ADVISED BY THE TRUSTEE AND HE DID NOT NOTIFY
THE COURT AND STILL PROCEEDED TO HARM APPELLANT MARYANN CASTRO ANDlTOT, THE
COURT^OW THE TRUTH ON OCT 30,2013 ftO(L HT^Uj-^nn Cft^ftO A^p/Z^n^
APPELLEE MANUEL CASTRO HAD NOT PAYED THE HOMEMORTGAGE HAD UNPAID ARREARS
AND IN HIS BANKRUPTCY PLAN THAT WAS BEING PAYROLL DEDUCTED IN THE PLAN THE
MORTGAGE HAD TO BE PAID TOO AND THAT WAS NOT BEING PAID HIS COUNSEL JOSEPH
APPELT LIED TO ALL JUDGES IN PRESIDING SAYING IT WAS DISCUSSED AND NOTED IT NEVER
WAS APPELLEE MANUEL CASTRO AGREED TO PAY THE MORTGAGE ON OR ABOUT OCT 2011
WHEN THE ACTUAL FILING FOR DIVORCE BEGAN AND IT WAS TO BE PAID IN HIS BANKRUPTCY
PLAN AND HE DID NOT FOLLOW THE PLAN HE AGREED TO WHEN HE FILED BANKRUPTCY.
B)
WRIGHT VS WRIGHT NO. 11-07-00169-CV FRAUD ON THE COMMUNITY ^
APPELLEE MANUEL CASTRO WITH COUNSEL JOSEPH APPELTTURNED OVE#THE COURTA
COMPARATIVE MARKET ANALYSIS A REALTORS OPINION TO OVER VALUE THE COMMUNITY
1501 OLIVE AT 125,000 TO GAIN FRAUD EQUITY AT 40,000 WHEN THE COMMUNITY 1501
OLIVE DOES NOT HAVE EQUITY IT HAS ARREARS FROM BANKRUPTCY FILED BY APPELLEE
MANUEL CASTRO NONPAYMENTS OF MORTGAGE SEE BSI STATEMENT
IFTHE COMMUNITY 1501 OLIVE ST GOES INTO FORECLOSURE THERE WILL BE A NEGETIVE
AMOUNT OWED IN THE AMOUNT OF 60,000 APPELLANT MARYANN CASTRO HAS RETAINED
ATTORNEY MATTHEW OBREMEIER TO PROTECT HER INTEREST IN THE MARTIAL HOME 1501
OLIVE ST WHERE SHE RESIDES AT HER HOMESTEAD APPELLANTMARYANN CASTRO WAS
AWARDED THE HOME ON OCT 30,2013 WITH TERMS BUT DID NOT KNOW THE MARTIAL
HOME WAS IN ACTIVE BANKRUPTCY FILEMPPELLLEE MANUEL CASTRO
COUNSEL JOSEPH APPELT KNEW OF THE BANKRUPTCY AND THAT THE AUTOMATIC STAY LIFT
WAS NOT FILED BY APPELLEE MANUEL CASTRO AND TRUSTEE DID ADVISE THIS WAS NEEDED
TO BE DONE IN/ORDER TO PROCEED IN THE DIVORCE AND IT WAS IGNORED AND NOT DONE"
COUNSEL JOSEPH APPELLT KNEW THIS AND AS AN OFFICER OF THE COURT STILL PROCEEDED
IN THE DIVORCE AND AGREEMENT KNOWNG THE HARM THAT WAS BROUGHT UPON
APPELLANT MARYANN CASTRO
WHEN IN BANKRUPTCY THE PERSON WHO FILED HAS TO CLEAR WITH THE COURT TO
PROCEED IN DIVORCE AND THIS WAS NOt DONE BY APPELLEE MANUEL CASTRO AND
COUNSEL JOSEH APPELLT KNEW THIS AND DID NOT FOLLOW THE TRUSTEE ADVISE ONLY TO
HARM APPELLANT MARYANN CASTRO WITH AN AGREEMENT THAT WAS NOT CLEARED
THROUGH THE BANKRUPTCY COURT
APPELLEE MANUEL CASTRO OWED A HIGH DOLLAR AMOUNT AND WAS NOT PAYING THE
MORTGAGE
THE AGREEMENT IS NOT VALID IT WAS PREPARED UNDER FALSE , MISREPRESENTATION IT
CHANGES EVERTHING APPELLEE MANUEL CASTRO DID NOT HAVE PERMISSION FROM THE
BANKRUPTCY COURT TO PROCEED IN THE AGREEMENT FOR FINAL DIVORCE HIS BANKRUPTCY
WAS ACTIVE AND THE COMMUNITY 1501 WAS UNDER THE BANKRUPTCY COURT PROTECTION
APPPELLEE MANUEL CASTRO PUT THE MARTIAL HOME IN BANKRUPTCY AND CONSPIRED TO
POCKET 40,000 BY OVERVALUING THE COMMUNITY AND NOT PAYING THE HOMEMORTGAGE
THE BANKRUPTCY PLAN HE SIGNED UP WHEN HE FILED BANKRUPTCY ON OR ABOUT AUG
2012.THIS EQUITY WAS ZOMBIE MONEY NOT REAL MONEY MARTIAL FRAUD IN THE AMOUNT
OF 40,000 CREATE A NEW DIVORCE DECREE IN THE MARTIAL ESTATE CONCONSTITUTE TO A
JUST AND RIGHT DIVISION THE COMMUNITY ESTATE DIMINSHED BY MARTIAL FRAUD
OVERVALUED WITH A REALTORS OPINION.(Schlueter V.Schlueter,(Tex.l998)
C ) 3rd party MISTRESS NON SPOUSE CHRISTINA PACHECO WHO IS INVOLVED IN THIS
LAWSUITE HAD A REALTOR FRIEND PREPARE THE CMA-REALTORS OPINION TO BE USED IN
CIVIL COURT TO HARM APPELLANT MARYANN CASTRO SHOWING REALTORS OPINION TO
VALUE THE MARTIAL HOME AT 351,375 Appellee Manuel Castro aided and Sister Leila Silva
and Counsel Joseph Appelt. The Comparative Market Analysis- Realtors opinion it states not
to be used as an Appraisal and it was Appellant Maryann Castro has a Certified Appraisal
showing the Community to be Valued at 225,000 and that is an actual value tax value is the
same.
D) APPELLEE MANUEL CASTRO CONSPIRED TO HARM APPELLANT MARYANN CASTRO
KNOWING THE CERTIFIED APPRAISAL IS 225,000.AND THAT THERE IS NO EQUITY DUE TO NON
PAYMENT OF MORTGAGE INTEREST PENALTIES ATTORNEYS FEES THAT HAVE CAUSED A LOSS
IN THE EQUITY OF THE MARTIAL HOME 1501 OLIVE FRAUD WAS ATTEMPTED BY APPELLEE
MANUEL CASTRO AND COUNSEL JOSEPH APPELT AND THE NON SPOUSE MISTRESS CHRISTINA
PACHECO WHO CONSPIRED TO STEAL 40,000 ON PROPERTY SHE DOES NOT OWN OR HAVE
INTEREST IN BY PRESENTING TO THE COURT THE OVERVALUED REALTORS OPINION
OVERVALUING THE COMMUNITY AT $125,000 ON THE MARTIAL HOME APPELLEE MANUEL
CASTRO SHARED WITH APPELLANT MARYANN CASTRO KNOWN AS 1501 OLIVE ST. THERE WAS
NO REFINACE ALLOWED DUE TO BANKRUPTCY BY APPLEEE MANUEL CASTRO AND UNPAID
MORTGAGE CAUSING A NEGETIVE STATUS OF THE ACCOUNT APPELLANT MARYANN CASTRO
WAS NEVER NOTIFED OR INFORMED OF NEGETIVE STATUES ON THE HOME MORTGAGE
APPELLEE MANUEL CASTRO CAUSED BY NOT PAYING THE HOMEMORTGAGE IF APPELLANT
MARYANN CASTRO WOULD OF KNOWN THE TRUTH OF THE STATUS OF THE MORTGAGE
APPELLEE MANUEL CASTRO HID FROM THE COURT AND APPELLANT MARYANN CASTRO ON
OCT 30,2013 APPELLANT MARYANN CASTRO WOULD OF NEVER SIGNED THE AGREEMENT FOR
FINAL DIVORCE ON OCT 30,2013 THIS WAS HIDDEN FROM APPELLANT MARYANN CASTRO
APPELLEE MANUEL CASTRO DID THIS TO HARM APPELLANT MARYANN CASTRO CAUSING
EXTREME STRESS AND ALMOST LOOSING THE MARTIAL HOME TO FORECLOURE ON JAN
6,2015.
E) BANKRUPTCY PROTECTION APPELLEE MANUEL CASTRO WAS UNDER ON OCT 30,2013
SEE STATEMENT FROM THE COURT THE LIFT STAY NEVER FILED BY APPELLEE MANUEL
CASTRO AND MORTGAGE PAYMENTS NOT BEING MADE BY APPELLEE MANUEL CASTRO THIS
WAS HIDDEN FROM APPELLANT MARYANN CASTRO ON OCT 30,2013
APPELLANT MARYANN CASTRO PAID FOR STAY LIFT FOR APPELLEE MANUEL CASTRO UNDER
THE ADVISEMENT OF COUNSEL SARAH LISHMAN APPELLEE MANUEL CASTRO SHOULD OF PAID
PRIOR TO OCT 30,2013 IN ORDER TO PROCEED IN DIVORCE ON OCT 30,2013 THIS FEE WAS
APPELLEE MANUEL CASTRO RESPONSIBILTY AND APPELLANT MARYANN CASTRO IS ASKING
THE COURT FOR A REFUND HE FILED BANKRUPTCY NOT APPELLANT MARYANN CASTRO SHE
PAID IN ORDER TO PROCEED WITH DIVORCE
APPELLANT MARYANN CASTRO DID NOT BREAK ANY LAWS APPELLANT MARYANN CASTRO
DID NOT APPELLANT MARYANN CASTRO IS ASKING THE COURT FOR A JUST AND RIGHT
DIVORCE DECREE THAT IS CLEAN AND FAIR WITH NO FRAUD
THE DIVORCE PROCESS AND THE AGREEMENT FOR FINAL DIVORCE SHE DID NOT CONSPIRE TO
COMMIT FRAUD OR TRY TO STEAL EQUITY ON MORTGAGE THAT WAS OWED APPELLANT
MARYANN CASTRO HAS BEEN HONEST WITH THE TRUTH AND FOR OVER A YEAR HAS BEEN
TRYING TO PRESENT IT TO THE COURT THIS AGREEMENT HAS CAUSED EXTREME STRESS
FINACIAL HARDSHIP ALMOST LOOSING THE MARTIAL HOME DUE TO APPELLEE MANUEL
CASTRO DISHONSETY IN THE AGREEMENT FOR FINAL DIVORCE SIGNED OCT 30,2013.
E)
APPELLANT MARYANN CASTRO DID NOT KNOW THE HOME MORTGAGE WAS NOT BEING PAID
APPELLANT MARYANN CASTRO DID NOT KNOW APPELLEE MANUEL CASTRO HAD THE
MARTIAL HOME IN ACTIVE BANKRUPTCY APPELLEE MANUEL CASTRO AND THE MISTRESS
WITH APPELLEE MANUEL CASTRO SISTER DIVERTED MORTGAGE MAIL TO APPELLEE MANUEL
CASTRO SISTER LEILA SILVA HICKORY SHAWDOW REMOVED APPELLANT MARYANN CASTRO
FROM CONTACT PERSON ON HER OWN HOME MORTGAGE
SEE STATEMENT FROM WELLS FARGO APPELLANT MARYANN CASTRO EVEN RECEIVED
PICTURE SHOWING HER NAME BEING REMOVED MISTRESS SENT PICTURE VIA TEXT ON CELL
AND APPELLANT MARYANN CASTRQ WILL TURN OVER TO THE COURT OF APPEALS UPON
REQUEST IF NEEDED
F)
THIS IS WHY THE AGREEMENT FOR FINAL DIVORCE SHOULD BE REPOPENED AND VOIDED
MODIFIED AMENDED THERE IS FRAUD MISREPRESENTATION IN WHICH HARMED APPELLANT
MARYANN CASTRO WHO HAS BEEN THE ONLY ONE HOLDING ON TO THE MARTIAL HOME
1501 OLIVE IT WAS SCHEDULED FOR FORECLOSURE JAN 6,2015 AND APPELLEE MANUEL
CASTRO DID NOT AIDE IN STOPPING FORECLOSURE IT WAS APPELLANT MARYANN CASTRO
WHO PREVENTED FORECLOSURE FROM BSI BANK SEE COPY OF FORECLOSURE NOTICE AND
EMAIL FROM BSI ATTORNEY WITH APPELLANT MARYANN CASTRO ATTORNEY MATTHEW
OBREIMER WHO IS A FORECLOSURE LAW SPECIALIST NOW THE NOTE WAS SOLD TO SN
SERVICING CORPORATION AND APPELLANT MARYANN CASTRO HAS FILED FOR A LOAN
MODIFICATION TO LOWER THE MORTGAGE AND PUT THE UNPAID ARREARS AT THE END OF
THE NOTE DUE TO NON PAYMENT OF MORTGAGE APPELLEE MANUEL CASTRO RISKED THE
COMMUNITY 1501 OLIVE TO FORECLOSURE BY NOT PAYING THE MORTGAGE AND BY BEING
DISHONEST IN THE AGREEMENT FOR FINAL DIVORCE ON OCT 30,2013 .
G) SUMMARY OF ARGUMENT
APPELLEE MANUEL CASTRO ALLOWED FORECLOSURE ON JANUARY 6,2015 BSI FILED TO
FORECLOSE IN THE AGREEMENT IT STATES THE FOLLOWING MANUEL CASTRO IS AUTHORIZED
TO DO WHAT HE NEEDS TO PREVENT FORECLOSURE OF THE HOME WITHOUT HARMING
MARYANN CASTRO INTEREST APPELLEE MANUEL CASTRO DID NOTHING HE COMMENTED YOU
WERE PUTTING LIGHTS FOR CHRISTMAS KNOWING FORECLOSURE WAS GOING TO HAPPEN
APPELLEE MANUEL CASTRO SAID THE FOLLOWING I WAS GOING TO CRY APPELLANT WAS
SHOCKED TO HEAR THIS REMARK FROM APPELLEE MANUEL CASTRO WHO IS GAINFULLY
EMPLOYEED MAKES 21 HOURLY AND WORKS OVERTIME APPELLEE MANUEL CASTRO DID NOT
OFFER TO STOP FORECLOSURE OR TO REFUND APPELLANT MARYANN CASTRO HIS SHARE TO
STOP FORECLOSURE APPELLANT MARYANN CASTRO BORROWED 3500 TO STOP FORECLOSURE
SEE COPY OF CHECK AND WANTS TO BE REFUNDED APPELLEE MANUEL CASTRO DID NOTHING
TO PROTECT HIS INTEREST IN THE MARTIAL HOME 1501 OLIVE ST IT WAS APPELLANT
MARYANN CASTRO WHO CARRIED THE EXPENSE AND IS REQUESTING A REFUND FROM THE
COURTS APPELLEE MANUEL CASTRO WAS TO HAVE PREVENTED THE FORECLOSURE AND HE
DID NOTHING.
APPELLANT MARYANN CASTRO HAS REPAID THE LOAN AND WANTS TO BE REIMBURSED THE
3500 SHE IS NOT EMPLOYEED SHE HAD TO SEEK EMPLOYMENT DUE TO APPELLEE MANUEL
CASTRO NOT SUPPORTING HER INSTEAD APPELLEE MANUEL CASTRO USED THE COMMUNITY
FUNDS TO SUPPORT HIS AFFAIR WITH MISTRESS CHRISTINA PACHECO IF APPELLANT MANUEL
CAN AFFORD TO PAY FOR HIS MISTRESS THEN HE SHOULD PAY ALIMONY FOR APPELLANT
MARYANN CASTRO FOR SHE WAS LEGALLY MARRIED TO APPELLEE MANUEL CASTRO FOR 29
YEARS AND IS THE DISABLED SPOUSE WITHIN THE MARRIAGE HER DISABILTY DOLLAR
AMOUNT HAS DROPPED DUE TO HER TIME BEING EMPLOYEED AND THIS HARMED HER
FINANCIALLY APPELLEE MANUEL CASTRO DUTY WAS TO APPELLANT MARYANN CASTRO AND
HE HAS NOT FINANCIALLY SUPPORTED HER THROUGH THE PROCESS OF DIVORCE WHICH WAS
TO PAY THE MORTGAGE PAYMENT AND HE DID NOT INSTEAD PAID FOR HIS EXTRA MARTIAL
AFFAIR WITH THE NON SPOUSE MISTRESS CHRISTINA PACHECO.
APPELLANT MARYANN CASTRO DOES NOT HAVE A CATERING BUSINESS AS COUNSEL JOSEPH
APPELT HAD ATTACKED HER IN CONTESTING HER AFFIDAVIT OF INDIGENCY
APPELLEE MANUEL CASTRO KNEW OF APPELLANT MARYANN CASTRO DISABILTY NOW AND
DURING THE MARRIAGE HIS COMMENTS ARE YOU CAN WORK AND SHE CAN'T SHE IS UNDER
DOCTOR CARE AND HER DISABILTY FUNDS HAVE BEEN LOWERED DUE TO BEING EMPLOYED
APPELLANT MARYANN CASTRO WAS EMPLOYEED ONLY TO SUPPORT THE COMMUNITY 1501
OLIVE APPELLEE MANUEL CASTRO PUT IN BANKRUPTCY AND HAD NOT SUPPORTED THE
DEBTS OWED IN THE MARRIAGE OF MANUEL AND MARYANN CASTRO AND SUPPORT THE
COST OF LIVING NEEDS OF THE DISABLED SPOUSE APPELLANT MARYANN CASTRO
APPELLEE MANUEL CASTRO HAD NOT SUPPORT APPELLANT MARYANN CASTRO DURING THE
PROCESS OF DIVORCE AND ON THE FINAL DIVORCE AGREEMENT OCT 30,2013
APPELLANT MARYANN CASTRO SHOULD HAVE BEEN AWARDED ALIMONY SHE DID NOT GIVE
UP HER RIGHT S COUNSEL JOSEPH APPELT TAMPERED WITH THE AGREEMENT THE ORIGINAL
WAS NEVER FILED AND THERE WAS NO RECORD THAT'S WHY HE WAS PUSHING TO ENFORCE
THE AGREEMENT KNOWING THE FRAUD HE CONSPIRED WITH AND TAMPERED WITH THE
AGREEMENT FOR FINAL DIVORCE
APPELLANT MARYANN CASTRO HAS BEEN CHALLENGING THE AGREEMENT FOR OVER A YEAR
AND A HALF ANDTHE7IPW BEING PRESENTED TO APPEALS COURT THE EVIDENCE THAT
SHOWS THE TRUTH AS TO WHY THE DIVORCE SHOULD BE REOPEND AND REWRITTEN TO A
JUST AND RIGHT DIVORCE DECREE ALL COUNSEL JOSEPH APPPELT DID WAS PREVENT THE
TRUTH FROM BEING SPOKEN IN COURT AND COST APPELLANT MARYANN CASTRO 20,000 IN
ATTORNEY FEES AND APPPELLANT MARYANN CASTRO IS ASKING THE COUURT TO REFUND
HER DUE TO THE DISHONESTY OF APPELLEE MANUEL CASTRO AND COUNSEL JOSEPH APPELT
AND 3rd PARTY NON SPOUSE MISTRESS CHRISTINA PACHECO.
THAT IS WHY APPELLANT MARYANN CASTRO HAS THIS CASE IN APPEALS COURT FOR THE
TRUTH TO BE HEARD PRESENTED AND RULED WITH A JUST AND RIGHT DIVORCE DECREE NOT
THE FRAUD CONSPIRACY HIDING MARTIAL ASSETS TAMPERING WITH THE AGREEMENT FOR
FINAL DIVORCE THAT WAS COVERED UP ON OCT 30, 2013
COUNSEL JOSEPH APPELT ENFORCED THE AGREEMENT KNOWING APPELLANT MARYANN
CASTRO WAS CHALLENGING THE AGREEMENT HE TAMPERED WITH AND JUDGE BARBRA
NELLERMOC KNEW APPELLANT MARYANN CASTRO WAS IN COURT TO SPEAK ON HER RIGHT
TO PROTECT HER INTEREST AND LIFE IN THE AGREEMENT FOR FINAL DIVORCE ALLOWED
PREJUDICE ONLY LISTENED TO COUNSEL JOSEPH APPELT WHO IS KNOWN FOR NOT ABIDING
BY THE LAW DID HE NOT RUN FOR JUDGE AND TAMPERED WITH HIS OPPENTS SIGNES WITH
HIS DAUGHTER CAUGHT ON VIDEO COUNSEL JOSEPH APPELT TAMPERED WITH THE LIFE OF
APPLELLANT MARYANN CASTRO BY SPEAKING TO JUDGE PRIOR TO COURT BEING DISHONEST
THORUGHOUT THE WHOLE PROCESS OF DIVORCE IN THE MARRIAGE OF MANUEL AND
MARYANN CASTRO AND THE AGREEMENT FOR FINAL DIVORCE ON OCT 30,2013
HOW IS THAT FAIR FOR APPELLANT MARYANN CASTRO AND COUNSEL SARAH LISHMAN
SPEAKING TO JUDGES PRIOR TO COURT APPELLANT MARYANN CASTRO HEARD COUNSEL
JOSEPH APPELLT TELL SARAH LISHMAN HE HAD SPOKEN TO JUDGE SAUNAS PRIOR TO COURT
COUNSEL JOSEPH APPELTWAS ABUSING THE JUDICAL SYSTEM INSTEAD OF ACTING LIKE A
PROFESSIONAL OFFICER OF THE COURT HE WAS CONDUCTING HIMSELF IN MISCONDUCT BY
CONSPIRING IN FRAUD OVERVALUED COMMUNITY 125,000 FOR HIS CLIENT WITH REALTORS
OPINION LEGAL MALPRACTICE PROCESS A DIVORCE IN ACTIVE BANKRUPTCY KNOWING HIS
CLIENT HAVE NOT GOTTEN APPROVAL FROM BANKRUPTCY COURT HAD THE COMMUNITY
1501 OLIVE UNDER BANKRUPTCY CLIENT OWED AND HAD NOT MADE THE MORTGAGE
PAYMENTS HIDING MARTIAL ASSETS KEOGH PLAN PENSION AND 99 SUBARU AND 95
FLEETWOOD DOUBLEWIDE HE KEPT ATTACKING APPELLANT MARYANN CASTRO IN COURT
WHEN HIS CLIENT APPELLEE MANUEL CASTRO WAS COMMITING ADULTERY,FRAUD, TO HARM
APPELLANT MARYANN CASTRO.AND THAT IS WHY APPELLANT MARYANN CASTRO IS
CONTESTING THE AGREEMENT FOR FINAL DIVORCE AND THAT IS WHY IT SHOULD BE
MODIFIED APPELLANT MARYANN CASTRO WAS HARMED.
H) HIDING MARTIAL ASSETS A KEOGH PLAN PENSION 99 SUBARU AND THE 95 FLEETWOOD
THE FOLLOWING INFORMATION WAS WITHHELD FROM APPELLANT MARYANN CASTRO SHE
DID NOT GIVE UP HER RIGHTS TO THESE MARTIAL ASSETS.
IJAPPELLEE MANUEL CASTRO COUNSEL JOSEPH APPELT SUBMITTED A MOTION TO JUDGE
LITTLEJOHN THESE ASSETS WERE HIDDEN FROM APPELLANT MARYANN CASTRO AND SHE
WANTS HER RIGHT TO THE KEOGH PLAN PENSION AND THE 99 SUBARU.
J) THE 95 FLEETWOOD DOUBLEWIDE MOBILE HOME APPELLEE MANUEL CASTRO MISTRESS
CHRISTINA PACHECO WERE COMMITING FRAUD WITH THIS ASSET THAT WAS IN THE MARRIAGE
OF MANUEL CASTRO AND MARYANN CASTRO SENT TEXT TO APPELLANT MARYANN CASTRO
SAYING THE MOBILE HOME WAS SOLD TO THE HERNANDEZ FOR 7000 BY GREENTREE AND THAT
THERE WAS ATITTLE TRANSFER NO PAPER WORK . SEE TEXT THccf" LaJ frS? -Jc I kJU
K) APPELLEE MANUEL CASTRO SURRENERED HIS INTEREST ITS LISTED AS EXEMPTED DEBT IN THE
AMOUNT OF 15,445.93 LISTED IN SECTION E BANKRUPTCY OF APPELLEE MANUEL CASTRO AND
THIS WAS VERIFIED BY THE DAIVIS LAW FIRM APPELLANT MARYANN CASTRO ARGUED THE DEBT
WITH GREENTREE THE DEBT WAS OWED BY APPELLEE MANUEL CASTRO AND MARYANN CASTRO
AND WHY DID APPELLANT MARYANN CASTRO GET A 1099 IN HER NAME DEBT WRITTEN OFF TO
HER SOCIAL SECUITY NUMBER IT WAS SETTLED FOR 7000 AND IT WAS NOT SOLD TO THE
HERNANDEZ IT'S A MARTIAL ASSET AND APPELLANT MARYANN CASTRO DID NOT GIVE UP HER
RIGHT TO THIS ASSET AND DID NOT KNOW THE DEBT WAS SETTLED AND WRITTEN OFF IN HER
NAME ONLY THIS WAS DONE WITHOUT HER CONCENT APPELLANT MARYANN CASTRO WAS TOLD
THERE WAS A NOTE NOT TO BE CONTACTED WHO SET THAT UP REAMAINS UNKNOWN.
LjAPPELLANT MARYANN CASTRO CALLED THE DAVIS LAW FIRM HOW CAN APPELLEE MANUEL
CASTRO SURRENDER A MARTIAL ASSET WHEN IT'S A DEBT OWED BY BOTH AND PART OF THE
DIVORCE AND IT DOES SAY NOT TO MAKE ANY ACCOUNT CHANGES WHILE IN PROCESS OF
DIVORCE APPELLANT MARYANN CASTRO WAS TOLD HE CAN7HOW? THE COURT WAS NOT
NOTIFIED NOR WAS APPELLANT MARYANN CASTRO LAWS BROKEN TO HARM APPELLANT
MARYANN CASTRO ?HOW IS THAT JUSTICE? APPELLEE MANUEL CASTRO AND THE NON SPOUSE
MISTRESS WERE CHANGING ACCOUNT MATTERS PUTTING THE DEBT ACCURED IN THE MARRIAGE
OF MANUEL AND MARYANN CASTRO ON APPELLANT MARYANN CASTRO THE DEBT OF THE
MOBILE HOME WAS SETTLED WITH GREENTREE FOR 7000 AND WRITTEN OFF IN APPELLANT
MARYANN CASTRO NAME SOCIAL SECURITY THE 1099 SHE RECIVED FOR 2014 THE NOTE WAS
NOT SOLD TO THE HERNANDEZ ONLY AS RENT TO OWN WITH TERMS AND THEY HAVE NOT PAID
OR FOLLOWED AGREEMENT SEE COPY APPELLANT MARYANN CASTRO HAS SENT THE
HERNANDEZ PARTY IN SOMMERSET TEXAS A NOTICE TO PAY THERE ARE TWO TAX LEINS
2013,2014 FILED AGAINST THE 95 FLEETWOOD IN ATASCOSA COUNTY AND THERE IS NO TITTLE
TRANSFER THE 95 FLEETWOOD IS OWED TO APPELLANT MARYANN CASTRO AND SHE HAS
SUBMITTED TO THE COURT IN BEXAR COUNTY THE PROOF AND HAS SUBMITTED TO THE
HERNANDEZ 30 DAY NOTICE TO PAY OR REPOSSESSION WILL TAKE PLACE APPELLANT MARYANN
CASTRO IS NEEDING THE HELP OF THE COURT TO GRANT APPELLANT MARYANN CASTRO THE
PERMISSION AND IS NEEDING ALIMONY TO PAY THE UNPAID TAXES SEE COPY SHE CANNOT PAY
THE DEBTS OWED BY APPELLEE MANUEL CASTRO APPELLANT MARYANN CASTRO IS DISABLED
AND ON A FIX INCOME SEE SOCIAL SECURITY STATEMENT
M) THERE ARE TAXES THAT NEED TO BE PAID APPELLEE MANUEL CASTRO OWES TO THE MOBILE
HOME AND TO THE COMMUNITY AT 1501 OLIVE SHE HAS TRIED TO COMMUNITCATE WITH APPELLEE
MANUEL CASTRO ABOUT THESE MATTERS AND HE REFUSES TO SUPPORT KNOWING THE COUNTY OF
ATASCOSA CAN LEGALLY ENFORCE AND NOTICES HAVE BEEN SENT TO ENFORCE ON THE COMMUNITY
APPELLANT MARYANN CASTRO HAS BEEN PAYING MONTHLY THE TAXES THAT ARE OWED BY BOTH
APPELLEE MANUEL CASTRO NEEDS THE ALIMONY SUPPORT OF APPELLEE MANUEL CASTRO ~1~Q
APPELLANT MARYANN CASTRO IS DISABLED AND NOT EMPLOYED APPELLANT MARYANN CASTRO
CURRENTLY UNDER DOCTORS CARE.
M) FRAUD ON THE COMMUNITY AND MARTIAL ASSET
A FIDUCIARY DUTY EXISTS BETWEEN THE SPOUSES REGARDING THE COMMUNITY PROPERTY
AND APPELLEE MANUEL CASTRO DID CONSPIRE TO COMMIT FRAUD WITH THE AIDE OF HIS
MISTRESS NON SPOUSE CHRISTINA PACHECO BY PRESENTING TO THE COURT A FALSIFIED
COMPARTIVE MARKET ANALYSIS REALTORS OPINION AND IT SAYS NOT TO BE USED AS AN
APPRAISAL IT'S A REALTORS OPINION AND IT WAS USED TO TRY TO FALSELY GAIN FRAUD
EQUITY IN THE AMOUNT OF 125,000 TO POCKET 40,000 WHEN THE HOME CERTIFIED VALUE IS
225,000 NOT THE REALTORS OPINION PRESENTED ON OCT 30,2013 THE REALTORS OPINION IS
351,375 THERE ARE ONLY 3 HOMES IN THE AREA AND APPELLEE MANUEL CASTRO KNEW THIS
AND KNEW THE REALTORS OPINION SET UP BY HIS MISTRESS CHRISTINA PACHECO WAS
INCORRECT APPELLEE MANUEL CASTRO DID THIS TO HARM APPELLANT MARYANN CASTRO
AND IT DID MISREPRESENTINGTTHETOMMWITY VALUE U3iN1TA REALTbRSOPINI^N
INSTEAD OF APPELLANT MARYANN CASTRO CERTIFIED APPRAISAL 225,000 A FIDUCIARY DUTY
EXISTS BETWEEN THE SPOUSES AND APPELLEE MANUEL CASTRO WAS ALLOWING THE
MISTRESS TO HARM APPELLANT MARYANN CASTRO WITH THE REALTORS OPINION BY BEING
DISHONEST IN OVERVALUING THE COMMUNITY 1501 OLIVE ST 125,000 THE MARTIAL
PROPERTY THAT WAS SHARED BETWEEN APPELLEE MANUEL CASTRO AND APPELLANT
MARYANN CASTRO.( IN THE MARRIAGE OF MOORE 890.SW 2D 821,827,TEX-APP-AMARILLO
1994 NO WRITJIT IS CONSTRUCTIVELY FRAUD WHEN ONE SPOUSE DISPOSE OF THE OTHER
SPOUSE INTEREST IN THE COMMUNITY WITHOUT THE CONCENT OF THE OTHER SPOUSE
APPELLEE MANUEL CASTRO MISTRESS SENT TEXT TO APPELLANT MARYANN CASTRO SAYING
N)THE FOLLOWING TEXT WAS SENTTO APPELLANT MARYANN CASTRO BY 3rd PARTY NON
SPOUSE CHRISTINA PACHECO GREENTREE SOLD HERNANDEZ MOBILE HOME FOR 7000 AND
TITLE TRANSFER NO PAPERWORK THIS WAS A LIE APPELLANT MARYANN CASTRO JUST
DISCOVERED THE TRUTH 6/2015 THE 3RP PARTY NONSPOUSE MISTRESS CHRISTINA PACHECO
KEPT SENDING TEXT MESSAGES TO APPELLANT MARYANN CASTRO PRETENDING TO BE
APPELLEE MANUEL CASTRO SELL THE HOME THAT WAS SHARED BY APPELLEE MANUEL
CASTRO AND APPELLANT MARYANN CASTRO 3rd PARTY NONSPOUSE MISTRESS CHRISTINA
PACHECO CONSPIRED TO DISPOSE A MARTIAL ASSET THAT DID NOT BELONG TO HER VALUED
AT ALMOST 20,000 SEE TAX VALUE AND WAS TRYING TO SELL APPELLANT MARYANN CASTRO
MARTIAL HOME BY USING HER AFFAIR WITH APPELLEE MANUEL CASTRO AND
COMMUNICATING WITH COUNSEL JOSEPH APPELT WHO FILED A MOTION TO ENFORCE SELL
BY ENFORCING A REALTOR WHO SET UP THE FRAUD IN OVERVALUING THE COMMUNITY AT
OVER 125,000 IT WAS DENIED WITH DISRESPECT TO APPELLANT MARYANN CASTRO SHE WAS
DISPOSING ATTEMPTING TO DISPOSE AN ASSET THAT HAS VALUE AND THE MARTIAL HOME
1501 OLIVE APPELLANT MARYANN CASTRO SHARED WITH APPELLEE MANUEL CASTRO THE 3rd
PARTY MISTRESS WAS CONSPIRING TO STEAL,40,000 WITH APPELLEE MANUEL CASTRO
AIDING
0)ATASCOSA COUNTY HAS A TAX LEIN 2013,2014 TOTAL DUE 734.71 ON THE 95 FLEETWOOD
DOUBLEWIDE SEE COPY .APPELLANT MARYANN CASTRO HAS MADE CONTACT WITH THE
URBAN HOUSING AND DEVELOPMENT TO ASSURE THE TITTLE HAD NOT BEEN TAMPERED
WITH AND IT HAS NOT IT WILL NOT BE RELEASED TO ANYONE OTHER THAT APPELLANT
MARYANN CASTRO AND THE TITTLE WILL NOT BE RELEASED UNTIL THE TAXES ARE PAID
2013,2014 AND THEREFORE HAVE TWO LEINS AS OF 6/14/2015 APPELLEE MANUEL CASTRO
HAS BEEN NOTIFIED APPELLANT MARYANN CASTRO NEEDS TO ALIMONY TO MAINTAIN HER
COST OF LIVING IT WAS APPELLEE MANUEL CASTRO WHO COMMITED ADULTERY, AND FRAUD
AND HAS NOT SUPPORTED APPELLANT MARYANN CASTRO OR THE DEBT THAT OCCURRED IN
THE MARRIAGE OF MANUEL AND MARYANN CASTRO APPELLANT MARYANN CASTRO IS
DISABLED AND CANNOT SUPPORT THE MARTIAL DEBTS OCCURRED IN THE MARRIAGE OF
MANUEL AND MARYANN CASTRO BY HERSELF APPELLEE MANUEL CASTRO MAKES MORE
MONEY THAN APPELLANT MARYANN CASTRO APPELLEE MANUEL CASTRO DID CAUSE THE
MARTIAL DEBTS TOO AND SHOULD BE HELD LIABLE LIKE THE UNPAID MORTGAGE HE FAILED
TO PAY THAT WAS TO BE PAID TO SUPPORT APPELLANT MARYANN CASTRO INSTEAD HE USED
THE COMMUNITY FUNDS TO SUPPORT HIS EXTRA MARTIAL AFFAIRWITH 3rd PARTY MISTRESS
NON SPOUSE CHRISTINA PACHECO SEE TEXT SENT TO APPELLANT MARYANN CASTRO BY THE
3rd PARTY NON SPOUSE MISTRESS CHRISTINA PACHECO NOWORK NO MONEY NO HOUSE
PAYMENT COURT OR NOT SORRY NOW IS THAT NOT DISRESPECTING THE COURT AND THE
SPOUSE OF APPELLEE MANUEL CASTRO THE PAYMENTS WERE COURT ORDER AND APPELLEE
MANUEL CASTRO WAS AIDING THE 3rd PARTY MISTRESS CHRISTINA PACHECO IN
FRAUD,DISPOSING A MARTIAL ASSET,HIDING MARTIAL ASSETS, AND HARRASSING APPELLANT
MARYANN CASTRO ONLY TO HARM HER. APPELLANT MARYANN CASTRO IS ASKING THE
COURT TO REFUND HER FOR THE UNPAID MORTGAGE THAT APPELLEE MANUEL CASTRO DID
NOT PAY THAT WAS SUPPORT FOR APPELLANT MARYANN CASTRO SEE BSI STATEMENT
APPELLEE MANUEL CASTRO MISTRESS CHRISTINA PACHECO ATTEMPTED TO DISPOSE THIS
MARTIAL ASSET THAT HAS INTEREST TO APPELLANT MARYANN CASTRO AND IS A MARTIAL
ASSET THIS WAS DONE TO HARM APPELLANT MARYANN CASTRO.
PJJOHNSON CONTROL RETIREMENT AND ALIMONY.APPELLANT MARYANN CASTRO DID NOT
GIVE UP HER RIGHT TO ALIMONY AND THE MARTIAL ASSET JOHNSON CONTROL RETIREMENT
IN THE AMOUNT OF 11,000 AND IS REQUSTING THE APPEALS COURT FOR 10,000 FOR THE
MORTGAGE
ALIMONY FOR SUPPORT IN THE AMOUNT OF 1500 MONTHLY TO BE PAYROLL DEDUCTED
WEEKLY IN THE AMOUNT OF 375 APPELLANT MARYANN CASTRO IS DISABLED AND WAS THE
v yeiwis )
SPOUSE OF APPELLEE MANUEL CASTRO FOR 29 COUNSEL JOSEPH APPELT TAMPERED WITH
THE AGREEMENT TO CAUSE HARM TO APPELLANT MARYANN CASTRO THE AGREEMENT FOR
FINAL DIVORCE SIGNED OCT 30,2013 AND THAT IS WHY THE AGREEMENT FOR FINAL DIVORCE
NEEDS TO BE REOPENED AND MODIFIED APPELLEE MANUEL CASTRO AND COUSEL JOSEPH
APPELTAND 3rd PARTY NON SPOUSE MISTRESS CHRISTINA PACHECO DID HARM APPELLANT
MARYANN CASTRO WITH FRAUD.
rX Pf&feS . 99 SUBARU APPELLANT MARYANN CASTRO DID NOT GIVE UP HER RIGHT TO THIS MARTIAL
££>£> 9703, ASSET ITS NOT EVEN IN THE AGREEMENT FOR FINAL DIVORCE IT WAS HIDDEN FROM HER AND
IS ASKING THE COURT TO RETURN THE 99 SUBARUTO APPELLANT MARYANN CASTRO
APPELLEE MANUEL CASTRO WAS GIVEN A 99 FORD COUNTOUR AND STATES THE FOLLOWING
IT WAS STOLEN OR BROKEN IN MEDIATION SHE WAS TOLD THIS AND NO POLICE REPORT
FILED CAUSING A LOSS IN A MARTIAL ASSET AND DID NOT NOTIFY THE POLICE BUT THE
MISTRESS WAS SENDING TEXT TO APPELLANT MARYANN CASTRO FOR TITTLE APPELLANT
MARYANN CASTRO NEVER HANDED THE MISTRESS THE TITTLE WHO WAS PRETENIDING TO BE
APPELLEE MANUEL CASTRO THE 99 COUNTOUR WAS SOLD TO PAY FOR THE MISTRESS
DIVORCE APPELLLEE MANUEL CASTRO AIDED HER IN STEALING FROM APPELLANT MARYANN
CASTRO.
KEOGH PLAN PENSION APPELLANT MARYANN CASTRO DID NOT GIVE UP HER RIGHT TO THIS
ASSET THAT WAS HIDDEN FROM HER ITS NOT EVEN IN THE AGREEMENT FOR FINAL DIVORCE
APPELLANT MARYANN CASTRO WANTS HER SHARE SHE IS ENTITLED TO.
Q)
DEBTS THAT OCCURRED WITHIN THE MARRIAGE OF MANUEL AND MARYANN CASTRO
APPELLANT MARYANN CASTRO PRAYS FOR THE COURT TO GRANT HER 1500 ALIMONY THE
SUPPORT THAT IS NEEDED TO MAINTAIN A COST OF LIVING APPELLANT IS DISABLED AND
BECAME DISABLED WITHIN THE MARRIAGE OF MANUEL AND MARYANN CASTRO 29 YEARS
AND PREJUDICE WAS BROUGHT UPON HER DISABILITY RIGHTS AS A DISABLED SPOUSE IN A
MARRIAGE THAT EXCEEDED IN OVER 10 YEARS AND ENDED DUE TO APPELLEE MANUEL
CASTRO CARRYING AN EXTRA MARTIAL AFFAIRWITH 3rd PARTY NON SPOUSE MISTRESS
CHRISTINA PACHECO LISTED IN THIS LAWSUITE IN THE AGREEMENT FOR FINAL DIVORCE
APPELLANT MARYANN CASTRO SOCIAL SECURITY HAS DROPPED TO DUE THE NONSUPPORT
OF APPELLEE MANUEL CASTRO WHERE SHE HAS BEEN THE ONLY ONE SUPPORTING THE
MARTIAL HOME PREVENTING FORECLOSURE FROM THE BANK AND THE ATACOSA TAX OFFICE
BY FUNDING THE EXPENSE THAT APPELLEE MANUEL CASTRO IGNORES AND REFUSES TO PAY
AND SUPPORT A DEBT THAT WAS CAUSED BY HIS DISHONESTY IN THE AGREEMENT FOR FINAL
DIVORCE SIGNED OCT 30, 2013.
BREACH OF FIDUCIARY DUTY BY FRAUD SEPT 1, 2011 THE TEXAS LEGISLATURE ADDED7.009 TO
THE TEXAS FAMILY CODE WHICH MANDATES COURTS TO RECONSTITUTE THE COMMUNITY
ESTATE UPON FINDING FRAUD. IN ADDITION, ACTS BY EITHER SPOUSE RESULTING IN
EXCESSIVE OR ABNORMAL EXPENDITURES,DESTRUCTION, CONCEALMENT,OR FRAUDULENT
DISPOSITION OF COMMUNITY PROPERTY, JO|NT TENANCY, OR OTHER PROPERTY HELD IN
COMMON IS A FACTOR FOR A COURT TO CONSIDER IN AWARDING SPOUSAL MAINTENCE.
WHAT CONSTITUTES FRAUD A. SPRICK V. SPRICK ,25 S.W. 3D 7(TEX.APP-EL PASO
1999,PET.DENIED)COMMUNITY FUNDS EXPENDED ON PARAMOURS
MATERIAL THAT WAS MISREPRESENTED ACTUAL FRAUD STONEV. LAWYERS TITLE INSURANCE
CORP., 554 S.W.2D 183,185(TEX 1977)
A BREACH OF FIDUCIARY DUTY IS FREQUENTLY TERMED AS FRAUD ON THE COMMUNITY IN
RE MARRIAGE OF MOORE, 890 S.E.2D 821,827(TEX.APP-AMARILLO 1994,NO WRIT)
CONSTRUCTIVE FRAUD INCLUDES ACTIONS OF ONE SPOUSE UNFAIRLY DISPOSING OF OR
ENCUMBERING THE OTHER SPOUSE INTEREST IN COMMUNITY PROPERTY OR UNFAIRLY
INCURRING COMMUNITY INDEBTNESS WITHOUT THE OTHER SPOUSES KNOWLEDGE OR
CONCENT. MASSEY V.MASSEY,807 S.W. 2D391,402(TEX.APP-HOUSTON[1ST
DISTRICT]1991)WRIT DENIED,867 S.W. 2D 766(TEX.1993)CONFIDENCES THAT EXIST AS A
RESULT OF THE MARRIAGE.ID.AT 827.
THE FOLLOWING DEBTS OCCURRED IN THE MARRIAGE OF MANUEL AND MARYANN CASTRO
MORTGAGE UNPAID ARREARS SEE BSI STATEMENT- SEE STATEMENT
APPELLEE MANUEL CASTRO OWES THE DEBT AND CAUSED THE DEBT TO EXCEED DUE TO HIS
DISHONESTY.
TAXES
95 FLEETWOOD 2013,378.81 2014 355.90 SEE STATEMENT
"1501OLIVE MARTIALHOME BALANCE FOR 2013-$725 SEE STATEMENT APPELLANT MARYANN-
CASTRO PAID 900 DID NOT KNOW TAXES WERE NOT BEING PAID AND DID NOTIFY APPELLEE
MANUEL CASTRO.
ATTORNEY FEES COST 20,000 IN 3 YEARS APPELLANT MARYANN CASTRO HAS PAID FOR
APPELLEE MANUEL CASTRO DISHONESTY AND EXTRA MARTIAL AFFAIR PRAYS FOR THE COURT
TO REFUND HER FOR IT WAS MANUEL CASTRO WHO COMMITED FRAUD AND ADULTERY WITH
THE 3rd PARTY NON SPOUSE MISTRESS CHRISTINA PACHECO APPELLANT MARYANN IS NOT
EMPLOYED AND HAS DISABILTY INCOME IN THE AMOUNT OF 854 MONTHLY AND PRAYS THE
COURT TO GRANT HER ALIMONY SPOUSAL MAINTENCE IN THE AMOUNT OF 1500 MONTHLY.
STUDENT LOAN DEBT IN THE AMOUNT OF 35,000 THIS WAS USED WITHIN THE MARRIAGE OF
MANUEL AND MARYANN CASTRO AND IS INDEFFERMENT SEE COPY
TOTAL DEBT AS OF JUNE 16,2015 TOTALS TO THE AMOUNT OF 116,459.71 APPELLANT
MARYANN CASTRO NEEDS THE SUPPORT OF APPELLEE MANUEL CASTRO APPELLEE MANUEL
CASTRO HAS CAUSED THIS DEBT AND HAS NOT SUPPORTED THE COMMUNITY IN THE
MARRIAGE OF MANUEL AND MARYANN CASTRO THAT ENDED WHEN HE BEGAN HIS EXTRA
MARTIAL AFFAIR ON OR ABOUT JULY 3,2011 AND HAS BEEN USING THE COMMUNITY FUNDS
TO FUND HIS EXTRA MARTIAL AFFAIR WITH 3rd PARTY NON SPOUSE MISTRESS CHRISTINA
PACHECO.APPELLANT MARYANN CASTRO PRAYS FOR THE COURT TO GRANT HER SUPPORT
ALIMONY IN THE AMOUNT OF 1500 MONTHLY TO BE PAYROLL DEDUCTED WEEKLY APPELLEE
MANUEL CASTRO HAD A FIDUCIARY DUTY TO APPELLANT MARYANN CASTRO AND APPELLEE
MANUEL CASTRO COMMITED CONSTRUCTIVE FRAUD TO DECEIVE APPELLANT MARYANN
CASTRO AND VIOLATED THE CONFIDENCE TO INJURE APPELLANT MARYANN CASTRO.
RELIEF FROM AGREEMENT
THE PURPOSE WAS TO DEFRAUD APPELLANT MARYANN CASTRO OUT OF THE FOLLOWING
HER HOMESTEAD THE MARTIAL HOME SHE HAS RESIDED AT SINCE 1995 APPELLEE MANUEL
CASTRO AND COUNSEL JOSEPH APPELT KNEW THE COMMUNITY WAS IN JEPORDY OF
FORCLOSURE AND HAD THE MARTIAL HOME IN ACTIVE BANKRUPTCY ON OCT
30,2013.CHANGE OF ADDRESS REMOVE APPELLANT MARYANN CASTRO NAME FROM
CONTACT PERSON WELLS FARGO NOTIFIED APPELLANT MARYANN CASTRO THAT CHRISTINA
PACHECO HAD TOLD THEM THE FOLLOWING REMOVE APPELLANT MARYANN CASTRO NAME
APPELLEE MANUEL CASTRO DIVORCE HER AND THIS WAS WHEN APPELLANT MARYANN
CASTRO HAD BEEN IN CONTACT WITH BANK CHECKING STATUS OF A LOAN MODIFICATION TO
LOWER MORTGAGE PAYMENT IT WAS 1789.45 AND WHEN APPELLANT MARYANN CASTRO
WAS NOTIFIED SHE WAS TOLD THAT THE REPRESENATIVE DESIREE DID TELL CHRISTINA
PACHECO APPELLANT MARYANN CASTRO NEEDS TO SEND IN A LETTER OF REQUEST DESIREE
WAS THE CONTACT PERSON THIS WAS DONE ABOUT 8/2012~AND THE NONSPOUSE-"
MISTRESS CHRISTINA PACHECO SENT PICTURE TO APPELLANT MARYANN CASTRO VIA PICTURE
SHOWING HER NAME REMOVED AND SENT NOTICE TO WELLSFARGO FORGING APPELLANT
MARYANN CASTRO NAME AND APPELLEE MANUEL CASTRO NAME AND MAIL FOWARDED TO
APPELLEE MANUEL CASTRO SISTER LEILA SILVA OF ELMINDORF WHO ALSO WAS INVOLVED IN
HARMING APPELLANT MARYANN CASTRO OF HER INTEREST IN THE MARTIAL HOME 1502
OLIVE.
THE NON SPOUSE MISTRESS ALSO SENT TEXT TO APPELLANT MARYANN CASTRO
QUESTIONING HER ABOUT DOCUMENT IS NEEDED FOR MODIFICATION BY BSI SEE TEXT ALSO
CALLING HER NASTY NAMES THE MISTRESS CHRISTINA PACHECO CONSPIRED TO COMMIT
FRAUD OF PROPERTY THAT IS IN THE MARRIAGE OF MANUEL AND MARYANN CASTRO TO
CAUSE HARM TO APPELLANT MARYANN CASTRO WITH THE AIDE OF APPELLEE MANUEL
CASTRO WHO ALLOWED THIS TO INTENTIONALLY HARM APPELLANT MARYANN CASTRO WITH
FRAUD.
APPELLEE MANUEL CASTRO MISTRESS CHRISTINA PACHECO HAS NO INTEREST IN ANY OF THE
ASSETS, MARTIAL HOME 1501 OLIVE, 95 FLEETWOOD MOBILE JOHNSON CONTROL AND
KEOGH RETIREMENT AND 99 SUBARU THAT WAS IN THE MARRIAGE OF MANUEL AND
MARYANN CASTRO THE MISTRESS HAS CONSPIRED IN FRAUD, THEFT, FORGERY, MAILFRAUD
AND APPELLEE MANUEL CASTRO AIDED IN CRUELTY TO HARM APPELLANT MARYANN CASTRO
DUE TO HIS EXTRA MARTIAL AFFAIR WITH CHRISITNA PACHECO FOR IT WAS APPELLEE
MANUEL CASTRO WHO COMMITED ADULTERY.
APPELLEE MANUEL CASTRO PUT THE COMMUNITY IN BANKRUPTCY WITH THE RISK OF
FORECLOSURE KNOWING HE WAS NOT MAKING THE MORTGAGE PAYMENTS AND
JEPORADIZING THE INTERST OF APPELLANT MARYANN CASTRO TO HARM HER ON JAN 6,2015
APPELLANT MARYANN CASTRO STOPPED FORECLOSURE FROM BSI APPELLEE MANUEL
CASTRO DID NOTHING HE WAS GOING TO ALLOW FORECLOSURE KNOWING APPELLANT
MARYANN CASTRO INTERST WOULD BE JEPORADIZE AND WOULD BE HOMELESS BSI BANK
LOWERED MORTGAGE TO 1600 BUT WANTED ARREARS ABOUT 45,000 SEE EMAIL FROM
ATTORNEY MATTHEW OBREMIER WHO HAS BEEN RETAINED TO PROTECT APPELLANT
MARYANN CASTRO INTERST IN THE MARTIAL HOME THAT SHE SHARED WITH APPELLEE
MANUEL CASTRO BSI BANK SOLD NOTE TO SN SERVICING AND APPELLANT MARYANN CASTRO
HAS SUBMITTED A LOAN MODIFICATION APPLICATION TO LOWER THE MORTGAGE AS OF
NOW ITS 1600 APPELLANT MARYANN CASTRO IS NEEDING ALIMONY SUPPORT BY APPELLEE
MANUEL CASTRO THAT SHOULD HAVE BEEN ENTERED OCT 30, 2013
APPELLANT MARYANN CASTRO INTEREST IS STILL AT RISK DUE TO NON PAYMENT OF
MORTGAGE PRIOR TO APPELLANT, MARYANN CASTRO BEING AWARDED THE MARTIAL HOME
1501 OLIVE APPELLEE MANUEL CASTRO HAD THE HOME IN ACTIVE BANKRUPTCY AND WAS
NOT PAYING THE MORTGAGE APPELLEE MANUEL CASTRO WAS PUTTING THE UNPAID DEBT
HE WAS TO HAVE PAID ON APPELLANT MARYANN CASTRO BY HIDING FROM THE COURT THE
BANKRUPTCY ACTIVE AND NON PAYMENT OF MORTGAGE AND THIS WAS DONE TO HARM
APPELLANT MARYANN CASTRO
"APPELLEE MANUELCASTROOVERVALUEDTHE COMMUNITY USINGA REALTORS OPlNrONTO
HARM APPELLANT MARYANN CASTRO AND IT DID ALMOST LOOSING THE MARTIAL HOME TO
FORECLOSURE ON 1/6/2015 APPELLLANT MARYANN CASTRO HAS DISCUSSED WITH APPELLEE
MANUEL CASTRO THE MATTERS OF THE MORTGAGE, TAXES, INSURANCE NEEDING SUPPORT
AND HE REFUSES SAYS HE HAS NO MONEY HE IS A WELDER AND MAKES 21 HOURLY WORKS
OVERTIME AND OWES A HIGH DOLLAR AMOUNT ON THE MORTGAGE HE DID NOT PAY IT IS A
DEBT HE CAUSED BY BEING DISHONEST AND CARRYING AN EXTRA MARTIAL AFFAIR WHEN
APPELLEE KNEW IT WAS COURT ORDER TO PAY.
APPELLLEE MANUEL CASTRO HAS BEEN USING THE COMMUNITY FUNDS TO FUND HIS AFFAIR
WITH MISTRESS CHRISTINA PACHECO WHO IS EMPLOYED AND HAS A HOME HE HAS BEEN
LIVING WITH HER DURING THE MARRIAGE OF MANUEL AND MARYANN CASTRO WHICH
ENDED DUE JULY 2011 APPELLEE MANUEL CASTRO COMMITED ADULTERY WITH NON SPOUSE
MISTRESS CHRISTINA PACHECO WHO IS PART OF THIS LAWSUITE AND NOT ENTITLED TO ANY
MONETARY FUNDS RETIREMENT KEOGH PENSION PLAN JOHNSON CONTROL RETIREMENT
ASSETS 95 FLEETWOOD MOBILE HOME,99 SUBARU,1501 OLIVE ST THE MARTIAL HOME
WHERE APPELLANT MARYANN CASTRO LIVES AND WAS AWARDED UNDER
MISREPRESENTATION THAT HOME WAS BEING PAID AND APPELLEE MANUEL CASTRO HAD
THE MARTIAL HOME IN ACTIVE BANKRUPTCY ON THE DAY THE AGREEMENT FOR FINAL
DIVORCE WAS SIGNED OCT 30,2013.
THE PRAYER APPELLANT REQUEST
REOPEN THE DIVORCE AGREEMENT AMEND MODIFY REWRITE THE AGREEMENT FOR FINAL
DIVORCE TO A JUST AND RIGHT DIVORCE DECREE APPELLANT MARYANN CASTRO WAS
HARMED AND THE APPELLANT BRIEF HAS STATES HER REQUEST AND TO INCLUDE 95
FLEETWOOD DOUBLEWIDE A MARTIAL ASSET THAT WAS HIDDEN FROM HER DISCOVERED
6/2015
APPELLANT MARYANN CASTRO PRAYS FOR RELIEF SHE WILL ACCEPT THE AWARD OF THE
MARTIAL HOME BUT NEEDS THE SUPPORT OF ALIMONY FOR COST OF LIVING IN THE AMOUNT
OF 1500 MONTLY IT WAS APPELLANT MARYANN CASTRCM&JHE ONLY WHO HAS PREVENTED
FORECLOSURE AND PROTECTED HER INTERST IN THE RESIDENCE 1501 OLIVE WHILE APPELLEE
MANUEL CASTRO WAS
MANUEL WAS CARRYING ON HIS
HIS EXTRA MARTIAL AFFAIR WITH 3rd PARTY NON
SPOUSE MISTRESS CHRISTINA PACHECO.
APPELLANT MARYANN CASTRO PRAYS FOR JUSTICE AND THE RELIEF SHE IS ENTITLED TO.
RESPECTFULLY
MARYANN CASTRO PRO-SE APPELLANT
1501 OLIVE
JOURDANTON TEXAS 78026 PACATTITUDE 2014@GMAIL.COM
830-496-0133
SENT 6/16/2015 AND DELIVERED TO APPELLEE MANUEL CASTRO AT 624 W. GOODWIN
PLEASANTON TEXAS 78026 BY NATALIE LUGO
- •-I. «,„u™ M CATJSENO. QD" -CXr &fo^-
ityt^ fMHtMSfML MTHEDISTJRICT COURT
^rf i^JUDICIALDISTRICT
VWf hMl&ttto BEXAHCOUNTY,TEXAS
{flL 0aiweflt) ac£reement for Pt'/vaJ Divfov^e^
Onthe O® day of QCaw6|£. .20 13 , came on to be heard the above styled
and numbered cause of action.
Perftjonerand Respondentappeared in personand annotmcedready. Afisr conference, the
parties reached an agreement onthe terms and conditionsset forth below.
By the signatures below the parries acknowledge that t M^>y."£ .#-• itire
understanding and accord oftae parties ia consentthat the Coxaf;'"f> •: ^±^<\ -.Av'-f"v, safer
binding orders in accordance with this agreement
ben-no lft£fr/4to^ feiffUfru ^8^14 U-gip/vi - ffi/^gaffiyY^PHtfa/fymhiS
^esftyEJtorta- (^AMfft^r"j(?UAf4fcAed ^mart-far O1^*82
tAt>tQDD £fo4M ^a^ ~k Mstod^flmo^dl Wtefrfein tome (Whey"
5. Oebfe t fetch Qojfox is y^-p^fe-fi/-fre. jfcHs.Vi>toiy mme^
Pags 1of2 Parties/Attorneys foaiaJs ftfy? /V\ f^C-*-'
CAUSE NO. jZ6[\ -f>X- 15°[ 5^- page.
All pa'feS nafia Wynj f„ ,11 [ , : • ——__
SK^mdENrafiH)Ml4is_3D_da7of_J2^fcg^
-20J3
APPROVED ASTOFORM;
"p"^Sa^SEs
AS^S""^
APPROVED AS T03POKMAND SDBSTANCF.
&_ ^"Ao> Ga^Ds
Ac oty&Y&r M^Mm^r fwdvfflft HV^&m^sK
© nff Mfce* Olive. Stvtet: Iwe is flmJbb fe> fag, vfc&Yiani-ed
'solA oral ^4otDOP sfoul foe* dU/a&tet 4-puCslb ^/^£idts>'f>rt>
aY^%&h"Bt%esWX£eAS> "' ^pi&^awrfcte?
i> MWjfWl Cftgfrp
J bA OBftteaterf^ fssoe/^
IQsp, ciete^Mviegl -Kmo -W fE^nqj^Urvp^ \-to ftto*j ^spH
it
E JM.C
\ \
f*\ f f*- 'T •!•': J ,'"-
IN THE MATTER OF H OCT !2 AH 9-S&0 IN THE DISTRICT COURT
THE MARRIAGE OF §
MANUEL G. CASTRO § 45TH JUDICIAL DISTRICT
AND 'BY_ S
MARY ANN CASTRO § BEXAR COUNTY, TEXAS
ORIGINAL COUNTERPETITION FOR DIVORCE
1. Discovery Level
Discovery in this case is intended to be conducted under level
2 of rule 190 of the Texas Rules of Civil Procedure.
2. Parties
This suit is brought by MARY ANN CASTRO, Counterpetitioner.
The last- three numbers of MARY-ANN CASTRO's driver's license number
are "7^ - The; last three numbers of MARY ANN CASTRO's Social
Security number are fff 5 .
; MANUEL G. CASTRO is Counterrespondent.
3. Domicile • ' ,
Counterpetitioner has been a domiciliary of Texas for the
preceding six-r^pnth periqd and a resident of this county for the
preceding ninety-day period.
4. Service
Service of this document may be had in accordance with Rule
21a, Texas Rules of Civil Procedure, by serving Counterrespondent's
attorney of record, JOSEPH P, APPELT, JR., 5825 Callaghan Rd, 104,
San Antonio, Texas 78228 in open court.
5. Protective Order Statement
No protective order under title 4 of the Texas Family Code is
in effect, and no application for a protective order is pending
with regard to the parties to this suit.
6. Dates of Marriage and Separation
The parties were married on or about July 21, 1984 and ceased
to live together as husband and wife on or about July 3, 2011.
7. Grounds for Divorce
The marriage has become insupportable because of discord or
conflict of personalities between Counterpetitioner and
Counterrespondent that destroys the legitimate ends of the marriage
relationship and prevents any reasonable expectation^ of
reconciliation,
Counterrespondent is guilty- of cruel treatment toward
Counterpetitioner of a nature that renders further living together
insupportable., -
Counterrespondeint has committed adultery.
8. Child of the Marriage
There is no child born or adopted of this marriage, and none
is ,expected. '"••>• 'A\ .-••'
9. \; Marital-Prpperty Agreement •
Counterpetitioner .and Counterrespondent will likely enter into
a marital-property agreement defining their rights to all their
property, both community and separate. Counterpetitioner requests
the Court to enforce the agreement and divide the marital estate in
accordance with its terms.
10. Separate-Property Confirmation
Counterpetitioner owns certain separate property that is not
part of the community estate of the parties, and Counterpetitioner
requests the Court to confirm such separate property as
Counterpetitioner's separate property and estate.
11. Reimbursement
Counterpetitioner .requests the Court to reimburse
Counterpetitioner \s separate estate for funds or assets expended by
Counterpetitioner's separate estate for the benefit of the
community. Those expenditures resulted in a direct benefit to the
community estafe. Counterpetitioner' s separate estate has not been
adequately compensated for or benefited from the expenditure of
thqse; funds or assets, and a failure by the Court to allow
reimbursement to Counterpetitioner's separate estate will result in
an unjust enrichment of the community estate at. the expense of
Counterpetitioner's separate estate. :.
12. Postdivorce Maintenance
The Cqunterpetitiqner also requests the Court to order that
she be paid postdivorce maintenance for a reasonable period in
accordance with chapter 8 of the Texas Family Code.
13. Request for Temporary Orders
Counterpetitioner requests the Court to dispense with the
issuance of a bond and after notice and hearing be temporarily
enjoined, pending the further order of this Court, from:
1. Communicating with Counterpetitioner in person, by
telephone, or in writing in vulgar, profane, obscene, or indecent
language or in a coarse or offensive manner.
2. Threatening Counterpetitioner in person, by telephone, or
in writing to take unlawful action against any person.
3. Placing one or more telephone calls, anonymously, at any
unreasonable hour, in an offensive and repetitious manner, or
without a legitimate purpose of communication.
4. Causing bodily injury to Counterpetitioner.
5. Threatening Coupterpetitipner with imminent bodily
injury,
<5. Destroying, removing, - concealing, encumbering,
transferring, or otherwise harming or reducing the value of the
property of one or both of the parties,
7.. Falsifying any writing pr record relating to the property
of either party.
: 8. Misrepresenting or refusing to disclose to
Counterpetitioner or to the Court, on proper request, the
existence, amount, or location of any property of one or both of
the parties.
9. Damaging or destroying the tangible property of one or
both of the parties, including any document that represents or
embodies anything of value.
10. Tampering with the tangible property of one or. both of
the parties, including any document that represents or embodies
anything of value, and causing pecuniary loss to Counterpetitioner.
11. Selling, transferring, assigning, mortgaging,
encumbering, or in any other manner alienating any of the property
of Counterpetitioner or Counterrespondent, whether, personalty or
realty,. and whether separate or community, except as specifically
authprdzed by order of this Court.
3.2. Incurring any indebtedness, other than legal expenses in
cpnnection with this suit, except as specifically authorized by
order, of this Court,
.13, Making withdrawals frpm any checking pr sayings account
in any financial ipstitution for;' any purpose, except as
specifically authorized by order of this Court. ,
14. Spendipg any sum of cash in Counterrespondent' s
possession or subject to Counterrespondent.' s ^control for any
purppse, except as specifically authorized by order of this Court.
15. Withdrawing or .borrowing in any manner for any purpose
frpm any retirement, profit-sharing, pension, death, pr other
emplpyee benefit plan or employee savings plan or from any
individual retirement account or Kedgh account, except as
5
specifically authorized by order of this Court.
16. Entering any safe-deposit box in the name of or subject
to the control of Counterpetitioner or Counterrespondent, whether
individually or jointly with others.
17. Withdrawing or borrowing in any manner all or any part of
the cash surrender value of life insurance policies on the life of
Counterpetitioper or Counterrespondent, except as specifically
authorized by order of this Court.
: 18. Changing or in any manner altering the beneficiary
designation on any life insurance on the life of Counterpetitioner
or Counterrespondent.
19. Canceling, altering, failing to renew or pay premiums, or
in any manner affecting the present lever of coverage 'of any life,'
casualty, automobile, or health insurance policies insuring the
parties' property or perspng. ••;-;"
• ' y20. Opening or diverting mail.addressed to Cpunterpetitiopgr.
,21. Signipg or endprsing Cpuhterpetitipher's hame on any
negotiable instrument, check, pr draft, such ajs tax refunds,
insurance payments, and dividends, or attempting to negotiate any
negotiable instrument payable to Coupterpetitipner without the
personal signature of Counterpetitioner.'. '.-
.22. Taking any action fp terminate or limit.credit or charge
cards in the name of Counterpetitioner.
23. Discontinuing or reducing the withholding for federal
income taxes on Counterrespondent's wages or salary while this case
is pending.
24. Destroying, disposing of, or altering any financial
records of the parties, including but not limited to records from
financial institutions (including canceled checks and deposit
slips), all records of credit purchases or cash advances, tax
returns, and financial statements.
25. Destroying, disposing of, or altering any e-mail or other
electronic data relevant to the subject matters of this case,
whether stored on a hard drive or on a diskette or other electronic
storage device.
26. Terminating or in any manner affecting the service of
wat^r, electricity, gas, telephone, cable television, or other
contractual services, such as security, pest control, landscaping,
or yard maintenance, at 1501 Olive,. JOurdanton, Texas 78026; 6026
Hazel Valley, San Antonio, Texas 78242 and/or 665 N. ;General
McMullen, San Antonio, Texas 78228 or in any manner attempting to
withdraw any deposits for service in connection with those
services. •'''•'-;•." •*' '.-;':•'••
'27. Excluding Counterpetitioner from the use and enjoyment of
the residence located at 1501 Olive, Jpurdantpn, Texas, 78026; 6026
Hctzel Valley, San Antonio, Te^xas 78242 andVpr .665 N. General
McMullen, San Antonio, Texas 78228.
7
28. Entering, operating, or exercising control over the 2003
Saturn and 1998 Dodge Van in the possession of Counterpetitioner.
Counterpetitioner requests that Counterrespondent be
authorized only as follows:
To make expenditures and incur indebtedness for reasonable and
necessary living expenses for food, clothing, shelter,
transportation, and medical care.
To make expenditures and incur indebtedness for reasonable
attorney's fees and expenses in connection with this suit.
•:•': •;.'";••-To make withdrawals from accounts in financial institutions
only for the purposes authorized by the Court's order.
Counterpetitioner requests that Counterrespondent be ordered
as follows:
To make payments to the Counterpetitioner for the support Qf
the Counterpetitioner pursuant to Texas Family Code; §6.502.
To make payments of reasonable interim attorney's fees and
expenses to Counterpetitioner's attorney pursuant to Texas, Family
Code §6.502. ";-i .:
14. Request for Temporary Orders Concerning: Use.of'Property *';
. ;Counterpetitioner requests the Court, after, notice and
hearing, for the preservation of the property and protection of the
parties, to make; temporary orders and issue any 'appropriate
temporary injupctions respecting the temporary use. pf the parties'
property as deemed necessary and equitable, including but not
8
limited to the following:
Awarding Counterpetitioner exclusive use and control of the
2003 Saturn and 1998 Dodge Van and enjoining Counterrespondent from
entering, operating, or exercising control over it.
Awarding Counterpetitioner the exclusive use of the following
property and enjoining Counterrespondent from exercising possession
or control of any of this property: her personal property, lawn
tppls^'and 'any';pther/:items the; Court;, deems appropriate-, ' •'•'''''-'"'V '
15. Request for Temporary Orders for Discovery and Ancillary
Relief '\
Counterpekitiqner requests the Court, after notice and
hearing, for the preservation of the property and protection of the
parties, to make temporary orders for discovery and ancillary
relief as deemed necessary and equitable, including but not limited
to the following:
Ordering .Counterrespondent to, provide,; a'..sworn.': inventory and.
appraisement of §11 the separate/ and community property pwned'pr
claimed by the parties' and all debts and liabilities owed bv. the
parties substantially in the form and detail prescribed by the
Texas Family L§w Practice Manual (3rd ed) , fprm 7-1.
16. Attorney's, Fees,:Expensesr Costs, and Interest
It was necessary for Countefpetitipper to secure the services
of EDWARD P. PIKER, JR^ a licensed attorpey, •%o prepare^ and
prosecute this suit. To effect an equitable division of the*estate
of the parties and as a part of the division, judgment for
attorney's fees, expenses, and costs through trial and appeal
should be granted against Counterrespondent and in favor of
Counterpetitioner for the use and benefit of Counterpetitioner's
attorney; or, in the alternative, Counterpetitioner requests that
reasphable attorney's''fees, expenses/ and costs through trial and
appeal be taxed a§ costs and be ordered paid directly t°
Cpupterpetitioner's attorney, who may enforce the order in the
attorney's own name, Counterpetitioner requests postjudgment
interest as allowed by law.
17. Prayer
Counterpetitioner prays that citation and notice issue as.
required by law and that the Court grant a divorce and all other
relief requested in this counterpetitipn. . ^•/-
"- Counterpetitioner prays' that the Court, after notice, and
hearing, grant this, request for, a temporary .injunction.
-•VCounterpetitioperSprays fpr attorney's fees, expenses, costs',
apd interest as. requested above. . ">"'••.
.Counterpetitioner prays for general, relief.
. Respectfully .'submitted,
Edward P. Piker, Jr.
315 S, Main Avei -/-
San Antonio, Texas.18204
Tel: (2*10) 226-0026."
Fax: (210) 226-8402
10
UNITED STATES BANKRUPTCY COURT
WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION
In re: Case No. 12-52696 G
MANUEL GUADALUPE CASTRO JR.
Debtor(s)
CHAPTER 13 STANDING TRUSTEE'S FINAL REPORT AND ACCOUNT
Mary K. Viegelahn, chapter 13 trustee, submits the following Final Report and Account
of the administration of the estate pursuant to 11 U.S.C. § 1302(b)(1). The trustee declares as
follows:
1) The case was filed on 08/31/2012.
2) The plan was confirmed on 11/26/2012.
3) The plan was modified by order after confirmation pursuant to 11 U.S.C. § 1329 on
NA.
4) The trustee filed action to remedy default by the debtor in performance under the plan
on NA
5) The case was dismissed on 10/03/2014.
6) Number of months from filing to last payment: 25-
7) Number of months case was pending: 33.
8) Total value of assets abandoned by court order: NA .
9) Total value of assets exempted: $15.445.93.
10) Amount of unsecured claims discharged without payment: $0.00.
11) All checks distributed by the trustee relating to this case have cleared the bank.
UST Form 101-13-FR-S (9/1/2009)
033261 64204033294012
Receipts:
Total paid by or on behalf of the debtor $20,000.48
Less amount refunded to debtor $2,812.32
NET RECEIPTS: $17,188.16
Expenses of Administration:
Attorney's Fees Paid Through the Plan $2,700.00
Court Costs $0.00
Trustee Expenses & Compensation $1,181.52
Other $0.00
TOTAL EXPENSES OF ADMINISTRATION: $3,881.52
Attorney fees paid and disclosed by debtor: $500.00
Scheduled Creditors:
Creditor Claim Claim Claim Principal Int.
Name Class Scheduled Asserted Allowed Paid Paid
ATASCOSA COUNTY Secured 1,569.41 1,298.30 1,298.30 0.00 0.00
ATASCOSA COUNTY Secured 402.66 420.84 420.84 0.00 0.00
Bexar County Clerk Unsecured 798.00 NA NA 0.00 0.00
BSI FINANCIAL SERVICES INC Secured 34,554.10 37,478.58 37,478.58 13,306.64 0.00
BSI FINANCIAL SERVICES INC Secured 222,286.00 251,847.20 251,847.20 0.00. 0.00
Bus & Prof Svc Unsecured 252.00 NA NA 0.00 0.00
City Employees Federal Unsecured NA NA NA 0.00 0.00
GENERATIONS FEDERAL CREDIT UN Unsecured 4,910.00 4,910.03 4,910.03 0.00 0.00
GENERATIONS FEDERAL CREDIT UK Unsecured 5,868.00 5,868.30 5,868.30 0.00 0.00
GENERATIONS FEDERAL CREDIT UK Unsecured 7,614.00 7,614.16 7,614.16 0.00 0.00
GREEN TREE SERVICING, LLC AS SE Secured 6,000.00 6,157.81 0.00 0.00 0.00
GREEN TREE SERVICING, LLC AS SE Secured 18,792.00 26,553.11 26,553.11 0.00 0.00
INTERNAL REVENUE SERVICE Priority 869.56 761.78 761.78 0.00 0.00
INTERNAL REVENUE SERVICE Unsecured NA 126.95 126.95 0.00 0.00
Med Data Sys Unsecured 113.00 NA NA 0.00 0.00
PALISADES ACQUISITION DCLLC Unsecured NA 234.95 0.00 0.00 0.00
UST Form 101-13-FR-S (9/1/2009)
033261 64204033294012
Semmary of Disbursements to Creditors:
Claim Principal Interest
Allowed Paid Paid
Secered Payments:
Mortgage Ongoing $0.00 $0.00 ' $0.00
Mortgage Arrearage $37,478.58 $13,306.64 $0.00
Debt Secured by Vehicle $0.00 $0.00 $0.00
All-Other Secured $280,119.45 $0.00 $0.00
TOTAL SECURED: $317,598.03 $13,306.64 $0.00
Priority Unsecured Payments:
Domestic Support Arrearage $0.00 $0.00 $0.00
Domestic Support Ongoing $0.00 $0.00 $0.00
All Other Priority $761.78 $0.00 $0.00
TOTAL PRIORITY: $761.78 $0.00 $0.00
GENERAL UNSECURED PAYMENTS: $18,519.44 $0.00 $0.00
Disbursements:
Expenses of Administration $3,881.52
Disbursements to Creditors $13,306.64
TOTAL DISBURSEMENTS : $17,188.16
12) The trustee certifies that, pursuant to Federal Rule of Bankruptcy Procedure 5009,
the estate has been fully administered, the foregoing summary is true and complete, and all
administrative matters for which the trustee is responsible have been completed. The trustee
requests a final decree be entered that discharges the trustee and grants ,such other relief as may
be just and proper.
Dated: 05/21/2015 By:/s/ Mary K. Viegelahn
Trustee
STATEMENT: This Unified Form is associated with an open bankruptcy case, therefore, Paperwork Reduction
Act exemption 5 C.F.R. § 1320.4(a)(2) applies.
UST Form 101-13-FR-S (9/1/2009)
033261 64204033294021
SI mam-
Services, inc.
10/09/2014
MANUEL G CASTRO JR
1501 OLIVE ST
JOURDANTON, TX 78026-2220
Loan Number: 44675
Property Address:' 1501 OLIVE STREET
JOURDANTON, TX 78026
NOTICE OF DEFAULT AND INTENT TO ACCELERATE
Dear MANUEL G CASTRO JR:
This letter is formal notice by BSI Financial Services, Inc. (herein as "BSI") the Servicer of the
above-referenced loan, on behalf of MLB SUB I, LLC that you are in default under the terms of the documents
creating and securing your Loan described above, including the Note and Deed of Trust/Mortgage/Security
Deed ("Security Instrument"), for failure to pay the amounts due.
The loan is due for 12/01/2011 and subsequent payments, plus late charges, fees and costs. As of today, the
total delinquency and reinstatement amount is $73,967.02, which consists of the following:
Next Payment Due Date 12/01/2011
Total Monthly Payments Due: $66,367.76
(35 @$ 1,732.72)
Late Charges $4,204.26
Other Fees: $3,395.00
Unapplied Balance: ($0.00)
TOTAL YOU MUST PAY TO CURE $73,967.02
It is possible that after payment of the amounts detailed above there may be other fees still due and
owing, including but not limited to other fees, escrow advances or corporate advances that BST paid on
your behalf or advanced to your account.
This letter is a formal demand to pay $73,967.02. If the default, together with additional payments that
subsequently become due, is not cured by 11/13/2014, BSI will accelerate the note so that the entire debt is
immediately due and payable, and take steps to terminate your ownership in the property by a foreclosure
proceeding or other action to seize the property.
IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, BSI offers consumer assistance
programs designed to help resolve delinquencies and avoid FORECLOSURE. These services are provided
without cost to our customers. You may be eligible for a loan workout plan or other similar alternatives. If you
would like to learn more about these programs, you may contact the Loss Mitigation Department at (800)
327-7861, Monday-Wednesday 8 am to 8 pm EST, Thursday 8 am to 6 pm EST, Friday 8 am to 5 pm EST,
Saturday 8 am to 12 pm EST. WE ARE VERY INTERESTED IN ASSISTING YOU.
The default above can be cured by payment of the total delinquency and reinstatement amount plus any
TX_NOI
Page 1 of 3 S2AiaM0ciM7
Comparative Market Analysis
Property At:
Prepared For:
Manuel Castro
1501 Olive
Jourdanton, TX 78026
\ Prepared By:
*^_r* Archie Marmolejo
_T All Season Realty
51HV>G SOUTH T53W5
AJI Season
Realty
Office Phone: (830) 281-5263 I
Direct Line: (210) 347-7330 ,
Personal Fax Number: (210) 569-6211
Email: marmoiejoarchie@aol.com
THIS IS A BROKER PRICE OPINION OR COMPARATIVEMARKET ANALYSIS AND SHOULD NOT BE CONSIDEREDAN APPRAISAL. In
making any decision that relies upon my work, you should know that I have not followed the guidelines for development of an appraisal
or analysis contained in the Uniform Standardsof ProfessionalAppraisal Practice of the Appraisal Foundation.
Prepared By: Archie Marmolejo All Season Realty
*^•vmjuxvi/
"s • ••} ^-cm jcsiaie community
Page 1 of 20
Comparative Market Analysis
Property At: 1501 Olive Street
Prepared For:
Maryann Castro
1501 Olive Street
Jourdanton, TX 78026
Prepared By:
Karen Potts
Dowdy Real Estate, LLC
Office Phone: (830) 569-6883
DirectUne: (830) 569-6883
Personal Fax Number:
Email: karen@dowdyrealestate.com
rage iy ui zu
Seller's Statement
Property At: 1501 Olive Street
Prepared For: Maryann Castro
1501 Olive Street
Jourdanton, TX 78026
\ -
Suggested Marketing Price: $184,000
c- \ -
Comparative Market Analysis
Property At:
Prepared For:
Manuel Castro
1501 Olive
Jourdanton, TX 78026
> Prepared By:
r* Archie Marmolejo
_r All Season Realty
o —
cy^m«Vc%\f 4j
5EHTO.G SOUTH TsiWS
All Season
Realiy
Office Rhone: (830) 281-5263
Direct Line: (210) 347-7330
Personal Fax Number: (210) 569-6211
Email: marmoiejoarchte@aol.com
THIS IS A BROKER PRICE OPINION OR COMPARATIVE MARKET ANALYSIS ANDSHOULD NOT BECONSIDERED AN APPRAISAL. In
making any decision thatrelies upon my work, youshouldknow thatI have not followedthe guidelines fordevelopment ofan appraisal
or analysis contained in the Uniform Standards of Professional Appraisal Practice of theAppraisal Foundation.
Prepared By: Archie Marmolejo All Season Realty
Seller's Statement
Property At:
Prepared For: Manuel Castro
1501 Olive
Jourdanton, TX 78026
Suggested Marketing Price: $351,375
fl5
flUUrtW Iftlit tlUH I bflUC. rax:ziuo/>uouu
LOCATED AT: }
J 816S FM 2146 j
9.45 Acres. J. Poitivem Survey ff1. Abstract 123'
Jourdanton, TX 78026 } ill
FOR:
' Advantage Mortgage
6601 Blanco Road. Suits 100
San Antonio, Texas 78218
AS OF:
December 19,2006
BY:
Angela R. Overlay
13730 Adobe Walls Drive
Helotes. Texas 78023
(210)696-4400
Form IIA1 —TOTAL forWindows" appraisal softsai?by5 lamods, inc.—1-800-ALAMODE
1 U L. 1'IVIl l u n u L
V
Castro, Manuel
Uniform Residential Appraisal Report Fte#8308
comparable properties ci nanHy offered for sain in the subject neighborhood ranging in price fmm t 225.000 toS 255,000
comparable sales in Hb iabject nelgtiborhood wiitrJa tie past twelve months rawing in sale price tram S ??citnm 240,000
earcli G did El did not reveal any pri ir sales or transfers ofHie comparable sales for the year pilot Mthe date of sale ofthe comparable sale.
Pah joimefs) San AntonioMLS
Repoa£ tha resultsITEM
nf the research aim anajyin of fw(*i prior sale ortransfer
in irn-r ~ \
historyn<-u>n
of (liemm.
subject- *«.—
property.... and comparable
I **.
sates (report additional prior sales on page 3).1_
_._.-....-—t~—*-*————t
ITEM SUBJECT COMPARABLE SAUiiH COMPARABLE SALE #g COMPARABLE SALE #3
Dateof PriorSale/Transfer See Con mania
Price of Prior Sala/Tfansfer Below. None None
DaTaJource(s)~
Effecttre Dale of Data Sourest;!
Arcjlyte nf priorsaleortransfer history ofttieSidjtect property and comparablesafes The subject is undarconstruction and has nottransferred in the nasi as
period. Thesales
month period. used inthisaoi
The sales U3ad raisal havenottransferred
in this am iraisal have not transfeirprf inthe
in tti« 12months prior in
19 mnnth^ ndnr to fho
theabovenotedtransaction.
ahmn nntori fran^ofj^n
Sirnirrfary of Sales Comparison Approach Eqi al empha3ls was qivan all salea. Sale 1was superior In acreage and metal work shop. It was inferior in ago
and EvTnq area. Sale 2 was inferior inac eaaa and aaa. butsunerior inbaths.IMno ansa,oarage and swimming pool. Sale 3 was oqualIn site site.
butIterior Si value because itwaa locat idoutin thecounty. Itwas superior in baths, livinq areaand oarage. It wasnacassarv tousesalesthat
closed"over 6 monBis agoandtogoovt r6 miles for comparable salesduetothalow density ofdevelopment In thesubject's maiftat araaand the
need*for home sales on acreage tracts. The3ubiectis considered a "mini ranch" and those typesof residential properties are becoming increasingly
pijai in tha ntettet
popular
1
I Mealed Value by Sales Comparison Approach $ 225,000
Indicjtad Value by; SafesCompaiisonApproa Hi j 225,000 CostApproach(lfdevBliH)a™.
3. fme appraiser [dentified in this ippraisal report is either a sub-contractor or anemployee of the supervisory appraiser for the
appraisal firm), is qualified to perfo am tt» appraisal, and is acceptable to perform this appraisal under the a^icabl^f Mte taT
i
4. (This appraisal report complies
promulgated by the Appraisal Standards
dards Board of The Apprarsal Foundation and that were In place at the time this appraisal
report was prepared.
S. ff this appraisal report was transmitted
defined in applicable federal and/oi "eStVi™,^/ electronic record containing my "electronic signature," asthose terms are
state laws (excluding audio and video recordings), ora facsimile transmission of this
appraisal report containing a copy >r representation of my signature, Hie appraisal report shall be as effective, enforceable and
valid as if a paper version of this appraisal report wera delivered containing my original hand written signature.
SUPERVISORY APPRAISER (ONLY IF REQUIRED)
Signature ___
Name
CompanyName Oyerley Appraisal Se rvices. Inc. Company Name
Gomfjany Address T3730 Adobe Wal s Drive Company Address
HelojaS, Texas 78023
Teleriftone Number (210> 695-4400~ Telephone Number
EmalfAddress anqelaovertav(g)S3fa.rr EmailAddress
Date bf Signature and Report Decen her 2a. 2005 Date of Signature _
Effecbve Date of Appraisal DacembiM9,2QQ5 State Certification #
StaiBperBficaflbn # 1326255-r or State License #
orState-Ucsrtse# State
of Otter (describe) ______ . State #* ExpirationDate of Certification or License
SSf3j___.
fitpirafioh Dateof Certification or Licer se 06/30/06 SUBJECT PROPERTY
1 1
ADDRESS OF PROPERTY APPRAISED
1501 Ollva St i street
Joun ianton, TX 7S026
APPF AISED VALUE OF SUBJECT PROPERTY $ 225.000 rop8rty
LENlfcR/CUENT
Name Sabriha RanallWall
Cornfany Name AdvantageMortoana l
Comf any Address 6601 Blanco Roac Suite 100. San Antonio,
, from street
Teotas 78216
f.k.* m street
Email Address sranalliOloqixanllrte-COi n -*iM
Freddie Mac Form 70 March 2005 Page 6 of 6 Fannie Mae Form 1004 March 2005
Form 1004—"TOTAL'tor Windows" appraisal software by ala mode, inc. —1-800-ALAMQQE
Statement of Account
NOTICE: This is a statement of Taxes Due as of 06/01/2015 12:26:57PIV1
based upon the tax records of the tax office.
ATASCOSA COUNTY TAX OFFICE Property Information
1001 OAK STREET Property ID: 17471 Geo ID: 01239-00-000-001104
JOURDANTON, TX 78026 Legal Acres 9.4500
Legal Desc: ABS A01239 J POITEVENT SV-1,9.45 ACRES
Situs: 1501 OLIVE ST ,
DBA:
Exemptions: DP, HS
Owner ID: 87397 Ownership: 100.00% Value Information
CASTRO MANUEL & MARYANN Improvement HS: 159,770
PO BOX 495 Improvement NHS: 0
Land HS: 54,810
PLEASANTON, TX78064
Land NHS: 0.
Productivity Market: 0-
Productivity Use: o:
Assessed Value 214,580
Entity Description Pet. Ex Code Description
FMLR FARM TO MARKET ROAD 100.00% DP Disability
GAT ATASCOSA COUNTY 100.00% HS Homestead
SJO JOURDANTONISD 100.00%
WEV EVERGREEN WATER DIST 100.00%
Unpaid Bills Summary
Entity Year Statement ID Tax Rate Type Tax Due Disc/P&l Attorney Fees Total Due
FMLR 2013 53838 0:076000 L 87.22 25.30 16.88 129.40
GAT 2013 53838 0.340600 L 395.84 114.79 76.59 587.22
WEV. 2013 53838 0.006000 L 6.24 1.81 1.21 9.26
Total for Year 2013 489.30 141.90 94.68 725.88
Total For All Years 489.30 141.90 94.68 725.88
Total Due if Paid By 06/30/2015 725.88
Paid Refunds Summary
No Information on File.
*** End of Statement ***
NOTICE: This document is not a tax certificate and does not absolve a Taxpayer from tax liability in any way. If this document is found to be Page 1
in error, it may be corrected by the Collection Office listed above. Responsibility to pay the remaining taxes rests entirely with the Taxpayer,
True Automation. Inc.
as outlined in the Texas Property Tax Code.
Homes Mortgages Agents Local News
Fisrffipj'^iHyTijffffl^ijift
—1 ..
City, Zip, Neighborhood, Address orMLS# search
San Antonio Metro Area > 78026 > 1501 Olive Street, Jourdanton, TX 78026
1501 Olive Street Jourdanton, TX 78026
$216,240 $292,560
LOW
$254,400 HIGH
^
/ALUE ESTIMATE
Value Estimate $254,400 ? Beds
Payment Estimate $959/mo ? Baths Full
Rent Estimate $1,700 ? Baths Half
Tax Estimate $3,281 ? Sq Ft 2,404
/^s HomeScore 40 ? Lot Size 9.00
•^ InvestorScore 34 ? Construction
Last Sale Date 08/25/2000 Style
Last Sale Price -- Year Built 2005
i^st Hom€?sn373 S.W.3d 32 (Tex.
2012).
6. The Agreement purports to award Mary Ann the marital home, but obligates her to
refinance within a specified period of time. Exhibit B at 1 and "Attachment A." Mary Ann has
been unable to do so due to the home being subject to Respondent's ongoing bankruptcy
proceeding. SeeAffidavit of MaryAnn Castro, attached and incorporated herein as "Exhibit C."
7. Further, Manuel failed to make mortgage payments as he was ordered to do in the
temporary orders in this matter, and the home is in default to the tune of approximately
$60,000.00. Exhibit C. This information was concealed from Mary Ann at the time she entered
into the Agreement. But for her belief that the home was not in default, Mary Ann would not
have executed the Agreement with Manuel. Id.
8. In addition, at the time of the execution of the Agreement, Manuel presented a falsified
Market Analysis to Mary Ann, a true and correct copy of which is attached and incorporated
herein as "Exhibit D," which indicated that the house was worth $200,000.00 more than what is
was actually worth. This was tantamount to fraud upon the community and, as a result, the
Agreement was not a just and right division of the marital estate based upon the fraud committed
Motion toDeclare Agreementfor Final Divorce Void: Castro Page 2
by Manuel. But for Manuel's misrepresentation of the value of the home, Mary Ann would not
have executed the Agreement with Manuel.
9. Mary Ann subsequently learned that the Market Analysis was completed by a friend of
Manuel's lover. Exhibit C. Mary Ann thereafter obtained another Market Analysis, a true and
correct copy of which is attached and incorporated herein as "Exhibit E," revealing the disparity
between the market value proffered by Manuel and the actual market value of the home.
10. On March 12, 2014, Mary Ann filed a Motion to Rescind and/or Notice of Repudiation,
seeking to have the Agreement nullified by the Court based upon fraud by Manuel and the fact
that it violated the bankruptcy stay. At the hearing on said Motion, the Court determined that
because neither party had obtained a lifting of the bankruptcy stay it did not have authority to
make any determination that would affect property of the bankruptcy estate, including making
any ruling with respect to the Agreement. As such, the Court declined to hear the matter unless
and until the stay was lifted for such purpose.
11. Despite having full knowledge that Mary Ann was repudiating the Agreement and that
Mary Ann's counsel was seeking to have the Agreement declared void, Manuel presented the
Agreement to the bankruptcy court for its approval on June 4, 2014. See Motion to Approve
Agreement for Final Divorce Nunc Pro Tunc, a true and correct copy of which is attached and
incorporated herein by reference as "Exhibit F." This Motion was never served on Mary Ann's
counsel, Jamie L. Graham (who filed a Notice of Appearance on March 11, 2014). Mary Ann's
counsel only learned of Manuel's actions from a search of the bankruptcy court's online docket.
12. Upon learning that Manuel was attempting to have the bankruptcy court approve the
Agreement, on July 16, 2014 Mary Ann filed motions in the bankruptcy court objecting to such
Motion toDec/are Agreementfor Final Divorce Void: Castro Page 3
action, as well as to lift the automatic stay to allow a state court to hear her challenges to the
validity of the Agreement. This required her to retain additional counsel and incur substantial
additional legal fees.
13. On July 31, 2014, a hearing was held in the bankruptcy court on both Manuel's and
Mary Ann's motions. On information and belief Manuel's counsel misrepresented to the
bankruptcy court that the state court had already denied Mary Ann's attempt to have the
Agreement rescinded and/or declared void. The bankruptcy court declined to accept the
Agreement and ordered that the automatic stay would be lifted so that the parties could address
their concerns in state court.
14. At this time, pursuant to the lifting of the stay, Mary Ann seeks to have the Court
declare that the Agreement is void because it violates the automatic stay of the bankruptcy
proceedings. In addition or in the alternative, Mary Ann seeks to repudiate the Agreement
because it was procured by fraud committed by Manuel in grossly misrepresenting the value of
the home and in intentionally failing to inform Mary Ann that the home was in default due to his
failure to make mortgage payments as ordered. Further, its terms are illegal and/or impossible to
comply with, as Mary Ann cannot refinance the home as required by the Agreement without
further violating the automatic stay- a criminal offense.
15. Mary Ann seeks an award of her reasonable and necessary attorney's fees and costs in
both this proceeding and in the bankruptcy proceeding. Mary Ann was forced to retain counsel
and incur these attorney's fees and costs due to Manuel's failure to obtain a lifting of the stay
prior to entering into a property division, and Manuel's bad acts in attempting to get the
bankruptcy court's approval of the Agreement without notice to Mary Ann or her counsel, and at
Motion toDeclare AgreementforFinal Divorce Void: Castro Page 4
a time when he was fully aware that Mary Ann was challenging the validity of the Agreement
and had repudiated the Agreement.
Respondent/Movant Mary Ann Castro prays that this Court grant her request to Declare
Agreement for Final Divorce Void on the ground that it was executed in violation of the
automatic stay of the bankruptcy court, and in addition to or in the alternative, upon the ground
that it was procured by fraud, and is impossible and/or illegal to comply with its terms. In the
alternative, Mary Ann Castro prays that this Court find that she has sufficiently revoked her
consent to or repudiated the Agreement for Final Divorce, and it is therefore unenforceable.
Mary Ann Castro further prays for an award of her reasonable and necessary attorney's fees and
costs, and for such other and further reliefas she may be entitled at law or in equity.
Respectfully submitted,
Law Offices of Jamie L. Graham
310 S St. Mary's St, Suite 845
San Antonio, Texas 78205
Tel. (210) 308-6448
Fax:(210)308-5669
i Anne Lishman
State Bar No. 24086267
Jamie L. Graham
State Bar No. 24027335
Attorney for Mary Ann Castro
Mo/ion toDeclare Agreementfor Final Divorce Void: Castro Page 5
Notice of Hearing
The above motion is set for hearing on August 25. 2014 at 9:00 a.m. in the Presiding
District Court, Room 109 of the Bexar County Courthouse, 100 Dolorosa St., San Antonio,
Texas 78205.
Gloria Sal da Pi a
8/12/2014
SIGNED on
Presiding Judge
*th
43SIh District Court
Bexar County, Texas
Judge or Clerk
Certificate of Service
Icertify that atrue copy of the above was served on each attorney of record or party in
accordance with the Texas Rules of Civil Procedure on August 12, 2014.
^---•^rarah Anne Lishman
Attorney for Mary Ann Castro
Motion to DeclareAgreementfor FinalDivorce Void: Castro
Page 6
Aug. 12.2014 8:24AM No. 1316 P. 1
Affidavit of Mary Ann Castro
Mary AnnCastro appeared before mein person today and stated under oath as follows:
"My name is Mary Ann Castro. I am above the age of eighteen years, and I am fully
competent to make this affidavit. I amthemovant in the Motion to Declare Agreement forFinal
Divorce Void. The facts stated in (his affidavit are within mypersonal knowledge and are true
and correct
"On September 30,2011, my husband Manuel Castro filed for divorce. i^U-feaUtae^htak,
had ahttady-aedfoi-ChagtarJ^ hnnlmq?teyrand-te-1316 P. 2
"On or about December 1, 2013, I learned that Argentina Marmolejo was a friend of
Manuel Castro's lover, and thereforebecame suspicious of the MarketAnalysis that he provided
to me at the time I signed the Agreement for Final Divorce. I therefore had my own Market
Analysis prepared by Karen Potts, who appraised the home at a fair market value of only
$184,000.00.
'1 have mademultiple attempts to refinance the home, as per the terms of the Agreement
for Divorce, buthavebeen toldthat no lender will refinance while the home is still subject to the
Manuel Castro's bankruptcy proceeding. Further, I was told that Manuel Castro removed me as
an authorized person for the current mortgage holderto communicate with, and I have therefore
had an extremely difficult time getting information with respect to the status of the mortgage.
All mortgage statements were diverted from my address to Manuel Castro's sister's address, and
so I never received any information with respectto the status ofmortgage payments afterManuel
Castro was ordered to make those payments in the temporary orders.
"I had a credit report done, and from that I learned that the home is currently in default
for approximately $60,000.00.
Mary Ann Cqsjnro
SIGNED under oath before me on
K/m.^$l)dl a$>nj^
NotaryTublic, State of Texas
^{iX GINA S. VIUAGOM6Z
l*XJbF% Notary Public. Stale ofTe«s
"»\A\A* My Commission Exoi'es
$fcw
'"•:„",:«--v' ' •
Februory 27. 2017
~&>
Affidavit ofMaryAnn Castro Page 2
1UNITED^STATES Official Change Of Address
'POSTAL SERVICE, gMnfirm^tion LETTER
VERIFICATION REQUIRED YOUR OLD ADDRESS aw
©
©
Mail will be forwarded for the MARYANN CASTRO
following individual only: 23302 HICKORY SHADOW Z
MARYANN ELMENDORFTX 78112-6172
CASTRO
Your mail will be forwarded to your
NEW address, as you requested, —I
o
on: Sep 30,2014
m
i—
o
YOUR NEW ADDRESS
•5o
00000067002 MB 0.435 T:0004
Ifthe information contained on this page is
incorrect, or you have not received mail at
your new address for 10 Postal business
days or more, please call 1-800-ASK-USPS
•Mill II lli'lll'-ll'l'll1'!"1'''-!!!'!!"'
(1-800-275-8777). MARYANN CASTRO
If you need to view or cancel this PO BOX 495 >
CO
Change-of-Address Order or change the PLEASANTON TX 78064-0495
date to start forwarding your mail,visit
managemymove.usps.com and enter
the Confirmation Code: 1429 45011010 9450
m
Visit managemymove.usps.com to add your JO
email address and receive email reminders CO
of mailforwarding expiration dates.
NOTIFY CORRESPONDENTS MAIL FORWARDING EXPIRATION DATES
WHO SENO YOU MAIL
Mail forwarding may be available First Class Mail, Priority & Express.... Sep 30,2015
for up to 12 months and covers Newspapers, Magazines Nov 29,2014
only certain classes of mail. Packages' Sep 30,2015
To ensure delivery of all your mail Catalogs Not Forwarded2
and to avoid forwarding delays, Standard Mail Not Forwarded2
you should notify everyone who
1. Some restrictions apply 2. Unless requested by mailer
sends you mail.
IMPORTANT MESSAGES FROM THE U.S. POSTAL SERVICE
REGARDING YOUR MAIL FORWARDING REQUEST: WHY THE YELLOW LABELS?
Yellow labelsjihdicate the=,'::.#.j
Yellow stickers with your new address are placed on mail correspondent doesn't know,
forwarded by the U.S. Postal Service, To receive your mail faster, your new*a3dfessT?'!r''••i--;';*''-l'di
notify the sender of your new address.
If you receive maiUwith a
Please retain this Official Change of Address Confirmation page yellow label attached, notify the
for your records as local agencies and/or resources may require it sender of your new address.
for proof of your move.
..UU.JU. ,nh^U«..MU*»f*"
All of the paper used to produce the USPS'" Official Change of Address Confirmation Letter
was sourced from sustainable forests.
1 i n n 1 i m nnnn i i i n n i i n i n <^,i7.nRfi_nnnnfi7n
Wells Fargo Home Mortgage
s$ZW^M£m^& 1 Home Campus
lllllllll^ Des Moines, IA 50328-0001
mm.GOimQiR'TBM'&Mi
October 15,2013
MANUEL G CASTRO JR
23302 HICKORY SHADOW
ELMENDORF TX 78112-6172
Subject: Transfer ofthe servicing-.ofyour mortgage loan
Wells Fargo Home Mortgage loan number: 015CJ04467JM
Dear MANUEL CASTRO JR,
Effective November l,2013 the servicing ofyour mortgage loan is being transferred to BSI Financial Services,
Inc. While the transfer ofservicing is very common intoday's mortgage industry, we recognize itoften raises a
number of questions.
Since you may have questions about this change to your mortgage servicing, we're providing you with
information to help make this transition easier for you. Rest assured, this does not affect any terms or
conditions ofyour mortgage. This transfer simply affects how your mortgage is serviced, like where you send
your payments.
Please read the reverse side ofthis letter - The Notice ofAssignment, Sale orTransfer ofServicing Rights
provides you with important required Real Estate Settlement Procedures Act (RESPA) information.
Important payment information
Beginning on November 1, 2013, BSI Financial Services, Inc will begin receiving payments on your mortgage
loan As ofthe same date, Wells Fargo Home Mortgage will no longerbe accepting payments on such
mortgage loan, thereforeyou must make yourloan payments payable to BSI Financial Services, Inc and send
them to the following address:
BSI Financial Services, Inc
' P.O.Box660605
Dallas, TX 75266
BSI Financial Services, Inc will be sendingyou aletter that will include payment ™s^fon*-^™J°™L
receive payment instructions from BSI Financial Services, Inc before your next payment is due, please write
rourlo^xXr onyour checkor money order and mail it to BSI Financial Services, Inc at the address listed
above. •
notify them ofthechange in servicer.
^oU ha^wSJpSS)fMA Package, transfer ofyourWells Fargo servicedmortgage loan may eliminate
S aMuT10 hnk^your mortgage to your PMA qualifying relationship balance and may result myour combined
S^fiSS^the mmimum requiredfor the PMA Package monthlyservice fee waiver as well as certain
other PMA benefits.
Wells Fargo Home Mortgage isadivision ofWells Fargo Bank, N.A. NMLSR ID 399801
Page 1 of 3
:WELLS Return Mail Operations
Statement date 01/13/12
POBox 14411
FARGO Des Moines, IA 50306-3411
Loan number 0150044675
Property address
1501 OLIVE STREET
JOURDANTON TX 78026
Customer Service __ online
For informational purposes W
i—i
Fax '
yourwellsfargomortgage.com
1-866-278-1179
7JrJ Telephone
1-800-274-7025
Correspondence
•|]|l'"'lll[|hllTlll"TH hl'"| -IS'i'-E-'i-I-miI PO Box 10335
Hours of operation
Mon - Fri 7 a.m. - 8 p.m CT
Des Moines, IA 50306
1AB 00471/024.131/001039 0109 3 ACP8GI 708
1 Q IPayments
MANUEL G CASTRO JR ; PO Box 660455
1501 OLIVE ST Dallas TX 75266
JOURDANTON, TX 78026-2220
We accept telecommunications relay service calls..
Important messages
This statement is for informational purposes only.
Summary Our records indicate tb.at.your loan is subject to -
Payment (principal and/or interest, escrow) $1,745.85 Unpaid principal balance bankruptcy. The attached coupon reflects the
Current monthly payment 02/01/12 a-. 7/c pc Unpaidadvance balance calendar due date, not the contractual due date of
Unapplied balance the bankruptcy case. If you have any questions
Overdue payment(s) 04/01/11 - 01/01/12 $17,445.36 (ContactCustomer Serviceforyourpayoff balance)
regarding your loan, please contact your
Interest rate 6.950%
Unpaid late charge(s) $1,080.26 Interest paid year-to-date $1,288.99
bankruptcy attorney or our office.
Other charges $340.00 Escrow balance $1,154.82-
Total payment 02/01/12 $20,611.47
Activity since your last statement
This statementis forinformational purposes onlyand is beingprovided asa courtesy should youvoluntarily decide
to make your loan payments.Thisstatement should not be construed as an attempt to collect a debt or a demand for
payment contrary to any protections you may have received pursuant to your bankruptcy case.
Ifyouhave receiveda discharge, andthe loanwasnot reaffirmedin the bankruptcycase,wewill onlyexerciseour
rights as against the propertyandweare not attemptingany act to collectthe discharged debtfrom youpersonally.
Ifyour Planrequiresyouto makeregularpost-petition mortgagepayments directlyto the Bankruptcy Trustee, and
you chose to maintain your mortgage payment, any payment should be remitted to the Trustee or otherwise in
accordance with the Plan you filed with the Bankruptcy court.
Date Description Total Principal Interest Escrow Other
01/13 Payment $273.07 $1,288.99 $183.79 Unapplied $1,745.85-
01/12 Funds received $1,700.00 Unapplied $1,700.00
12/08 Funds received $1,700.00 Unapplied $1,700.00
Continued on the next Daae
024181/001039 ACP8GI S1-ET-M1-C009 1
Monthly payment
Loan number 0150044675 x pint arnt
WELLS
FARGO
Additional
principal
Check here and see MANUEL G CASTRO JR • Late r «~
reverse for address
charaes ~ ^
correction. 00471/024181/001039 0109 3 ACP8G! 708
Please specify
additional funds
Otha
D *£
.harges
|D|'i>i|ii|iiiiii||hi-ii'|iii'|'ii|igi'-'»'|'i-ii|i| iir
WELLS FARGO HOME MORTGAGE
PO BOX 660455 '"• Additional
DALLAS TX 75266-0455
Total amount enclosed
(Please do not sand cash) "•?
70A D1SDDM-MW7S 2 lDDDD17MSflSDlflS3,:iS2Dbim71c]niEl DDDDDDnDflDSSBiaTD? D
L J' YOUR OLD ADDRESS
f ' will be forwarded for the MARYANN CASTRO
fdiiuwing individual only: 23302 HICKORY SHADOW m
MARYANN ELMENDORFTX 78112-6172 S3
CASTRO m
Yourmail will be forwarded to your an
NEW address, as you requested, —I
o
on: Sep 30,2014 zn
m
r—
o
YOUR NEW ADDRESS o
O
00000067002 MB 0.435 T:0004 30
Ifthe information contained on this page is
OO
incorrect, or you have not received mail at
your new address for 10 Postal business
days or more, please call 1-800-ASK-USPS Ihll'HIII lli'in>ilm!i>Ml>l'i"«><»«ii!'ii"i g
I—
(1-8QQ-275-8777). MARYANN CASTRO cz
PO BOX 495 >
Ifyou need to view or cancel this ro
Change-of-Address Order or change the PLEASANTON TX 78064-0495 r—
m
date to start forwarding your mail, visit
managemymove.usps.com and enter O
the Confirmation Code: 1429 450110109450
m
Visit managemymove.usps.com to add your
email address and receive email reminders CO
of mail forwarding expiration dates.
•A..
c
*."\
BEXAR BOUNTY SHERIFF'S OFFICE
L
i. fReqwetf forrSheriffs Report
RV4/04 350-135
DATE
rfnfi\ District: ^cy^JCaseNo. ;/_ 3g5^
Name of Complainant:
Location^Incident: £%^j /jl£ (4(j £)\<%iloU>*
Type of Incident: 'fc'i^Ktr'j^vT^
Sheriffs Deputy Badge Phone:
2/A j APPGILG^
NOTE: If you wish to pursue criminal charges, please contact
the Criminal Investigations Division at (210)335-6070
~"JT:
«$•
CyflM'ti fL.ur
Ifyou have questions or concerns in thefuture regarding workout options )r
status ofthe loan, please" contact! ourBankruptcy Department at (800) 274
Representatives are available for assistance Monday through Friday, 7 a.m
Time.
Wells Fargo Home Mortgage is committed to serving the needs of our cusfc
any additional questions or need clarification regarding the information pn
contact me directly at (877) 491-0707, extension 65129. I am available to a:
through Friday, 9:00 a.m. to 6:00 p.m., Eastern Time
Sincerely,
m^.z^H
Rita Reilly
Written Customer Contact
Enclosure
->:
*hfLDd^Pte^iao^ -process y>c\s\y^q^ap^a^
We understand that your clients have filed for bankruptcy. We are not not attempting
attemptii to collect the mortgageage debt with this letter. Wefe are required
required I
by federal law to inform you that if your client's loan is currently delinquent or in default, as the loan servicer, we will be attempting to collect a
debt, and any information obtained will be used for that purpose. However, this letter should not be construed as an attempt to collect a debt or a
demand for payment contrary to any protections provided by the automatic stay of your client's bankruptcy case. If your clients have received a
discharge, and the loan was not reaffirmed in the bankruptcy case,
;ase, we
we will
will only exercise our rights as against the
the property and
and are
are not
not attempting
vS »'l-m Yprocess i /\OeM&tJ ^v>
04/W' No Data Available
K^
Amount Amount Due
*&&* S
03/^ $1,732 2/1/2014 $220,615 Conventional Re Mortgage
Additioftatlhtornriattopu Loan Modified; 180 Days or More Past Due
$258,108 61,732 $1,733 2/1/2014 $220,615 "Conventional Re Mortgage ^
itictiiahnJQ^atio'ri: Loan Modified; 180 Days or More Past Due
pr"^-"-""^
(Continued On Next Page) Page 5 of 62 4148034000010-001658549- 1641 - 2188 - ASD
w
12-52696-cag Doc#61 Filed 07/29/14 Entered 07/29/1416:34:44 Main Document Pglof3
UNITED STATES BANKRUPTCY COURT
WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION
§ CASE NO.: 12-52696G
IN RE: -
W +
MANUEL GUADALUPE CASTRO JR. § fl
§ 1 , ih
Debtor § 1.. . (' ,
• ••'.•:,
TRUSTEE'S AMENDED OBJECTION TO MOTION TO J .«•.
APPROVE AGREEMENT FOR FINAL DIVORCE NUNC PRO TUNC
AND REQUEST FOR HEARING !
TO THE HONORABLE JUDGE OF SAID COURT:
Now eon**, Mary K. Viegeiahn, Chapter 13 trastee and files ftis, her Cnapfcr 13 Tree's Amended
Objection to the above-referenced Motion.
The Chapter 13 Trostee does not approve the afore-mentioned motion for the following reasons:
neTra5<~oPpc*es,heMon=^
"tSS*S?SSSZt^r^le o7the home at ,501 Olive St Joardanton
SS^SIrtSK£ Sep.en.ber 21.»I2 reacts ava.ue ofS2353W.00with secar*
c^orW*,! and the Detaor -£^£^£^1^%£.
wrdVtt leaving the Debtor with non exempt tunds ot azo"i. *"*
£££ tf toCuIn on Debtor's Scheduis A«. _~ and fuestions 4= good fa* of the
Debtor's valuation on Schedule A.
TheMotion does not state how the mortgage arrears currently being paid*™^*D*"
I^rwill be treated. The Trustee questions who will
poperty wilt de
be taking over the funding of tins Popa*
disbursements on the mortgage arrears to BSI
.neluding *>"W ^be7g^ by through the plan. The property settlement agreement
has disbursed $7,347.09 to BSI Financial Services Inc. for the arrears.
* ,r+~-r, on rvrnher 10 2012 the Debtor was advised that a Motion to Lift the
T IS«Ssti°wingthe exeeotion ofthe property sett.en.en. on October 30,2013. As
without prior approval ofthis Court.
IT IS HEREBY ADJUDGED and DECREED that the
below described is SO ORDERED.
Dated: October 03, 2014.
CRAIG A. GARGOTTA
UNITED STATES BANKRUPTCY JUDGE
IN THE UNITED STATES BANKRUPTCY COURT
WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION
IN RE: § CASE NO. 12-52696-G
§
§
Manuel Guadalupe Castro, Jr. §
§
§
DEBTOR(S) §§ CHAPTER 13
ORDER APPROVING MOTION TO VOLUNTARILY DISMISS CHAPTER 13 CASE
On this date came on to be considered Debtor's Motion to Voluntarily Dismiss Chapter 13
case. The Court finds that such motion states sufficient grounds to be approved and that Debtor
has the right to voluntarily dismiss this case, without prejudice, as it has not been previously
converted from another chapter of the Bankruptcy Code.
It is, therefore, ORDERED that Debtor's Chapter 13 case be, and the same is hereby
DISMISSED without prejudice to re-filing.
###
Davis Law Firm
10500 Heritage, Ste. 102
San Antonio, Texas 78216
(210)444-4444
012362 77704012374017
w
12-52696-cag Doc#63-l Filed 09/04/14 Entered 09/04/14 20:37:39 Affidavit Pg 2of 35
4. Manuel G. Castro Jrand Mary Castro executed a Adjustable Rate Note dated March V,
2006. in favor ofWells Fargo Bank, N.A. in the original principal sum of SI 91 ?50 00 '
(the '"Note").
5. BSI FINANCIAL SERVICES. AS SERVICER FOR WELLS FARGO BANK, NA is ths
servicer of the loan and holds the Note. Hni
__(). The Note is secured by aRecorded Deed ofTrust encumberinc certain real property
commonly known as 1501 OLIVE STREET. JOURDANTON" TX 78026.
*ra>fe,
The unpaid principal balance ofthis loan as ofAugust 26.2014 is 5220,897.72.
8. The ratal post-petition arrearage due as of August 26, 2014 is 542.411.76. Please note
that additional payments will come due after September" I.'2014. Attiichea hereto as
^ee,
Exhibit "A" is asummary of the Debtor's post-payment history, including default
dates and amounts.
9. The sums set forth in this affidavit do not include any late charges, escrow advances
attorneys- fees, cost, orother fees and charges that might otherwise be included in the
event that a payoff is requested or provided.
10. The Note, and Supplemental Riders. Amendments, Modifications, Deed of Trust and
Assignments, ifany, are attached hereto as Exhibit "A" and are true and accurate copies
of the originals.
Further Affiant Saved! Not.
BY:
AFFIANT
Subscribed and s"*om to before me
s thisjjj^day ofifefrffi2014- by
U
'iftjiZIfl&Jjtfi
State of "PR^Q.^
My Commission expires: 3/ | / \f
Personally Known fej OR
Produced Identification ,
Type of Identification Produced:
w
12-52696-cag Doc#63-l Filed 09/04/14 Entered 09/04/14 20:37:39 Affidavit Pg 2 of 35
anuel G. Castro Jrand Mary Castro executed aAdjustable Rate Note dated March 07,
2006. in favor ofWells Fargo Bank, N.A. in the original principal sum of$19 J ?50 00
(the "Note").
BSI FINANCIAL SERVICES. AS SERVICER FOR WELLS FARGO BANK, N.A. is th
servicer of the loan and holds the Note.
6. The Note is secured by aRecorded Deed ofTrust encumberine certain real property
commonly known as 1501 OLIVE STREET, JOURDANTON" TX 78026.
7. The unpaid principal balance ofthis loan as ofAugust 26.2014 is 5220,897.72.
8. The rata! post-petition arrearage due as of August 26, 2014 is 542.411.76. Please note ^rOv_->
that additional payments will come due after September I, 2014. Attache3 hereto as *^X
Exhibit "A" is asummary of the Debtor's post-payment history, including default tlsKd<-A
dates and amounts. *—^%^U S\*
9. The sums set forth in this affidavit do not include any late charges, escrow advances. *
attorneys" fees, cost, orother fees and charges that might otherwise be included in the
event that a payoff is requested or provided.
JO. The Mote, and Supplemental Riders. Amendments. Modifications, Deed of Trust, and
Assignments, ifany, are attached hereto as Exhibit "A" and are true and accurate copies
of die originals.
Further Affiant Saveth Not.
BY:
AFFIANT
Subscribed and sworn to before me
i lhis^L_dayoffWWir20(4, by
tfafll'M.
State of "P*Xfl.^
My Commission expires: 3/ j / \f
Personally Known pj OR
Produced Identification .
Type of identification Produced:
—o9o-,aS Doc.63 ^09/04*4 Enters 09/04/1420.37:39 dSL *,J! Wft
v°w.- **»0"ab'
For »Rel,
"Aug>« 31.2012. MANUEL GOADALUPE CASTRO »
rf under Chapter 13]3 ofrf the Bankruptcy Code,
CASTR° Vu
*•"-***»**.a
therebv -.,- .
tyk"J&,
Bankruptcy Case. MARYK VlFTFf amm • , '' ^ * *"**««
IARVK. VIEGELAHN -he duly appointed andacting Chapter 13 W !-F' '
4- On March 07,2006 Vfami^i r r . , "
' mUd °- C"S,m Jr HK«WAojustabie RaK NoK ,. ... ., . . s
P"naP"mOUn,0fS]9,J5"*»*"*„fWe,lsFaioBM)tN/, —«^- :
May Castro is no, .c,b,ormth,statn,p,cy,ta;sprottciedbyiheC
adehor ir,«,-. K . Payn,a" °f " N<*=-
iSHSIH^™™=StK*? °* —* C0UNTY
ATTACHEDTOT„EDEE«^V^ AND BEING MADE PARTTCuJ^frS"Jf,***»;
Also known as:
1501 OLIVE STREET
JOURDANTON, TX 78026
The Deed ofT^twas duly recorded inATASCOSA County DeedRecords.
* Debtor alleges to be the ««* owner ofrecord ofAe Property ^ __ ,^
provides for direct ongoingpayments. ^ ^ 13 P,a»
7- Debtor is i„ defauJt „ & ."
8- As ofAug™ 26.20I4. *estMlsoffte ^ ^ ^bMmb_
c
"•«»* "P«PaIWanKd.ffl(lowingtoMovanton
theNi
b)
" am0m*™*="Vlool practice, rote, or order.
NO. 2011-CI-15957
IN THE MATTER OF
§ IN THE DISTRICT COURT
THE MARRIAGE OF
§
MANUEL G. CASTRO § 45 JUDICIAL DISTRICT
AND
§
MARY ANN CASTRO
§ BEXAR COUNTY, TEXAS
ORDER ONMOTION TQ DECLARE AGREEMENT FOR FINAL DIVORCE VOTD
On September 1.6, 2014 and September 29, 2014, the Court heard Movant Mary Ann
Castro's Motion to Declare Agreement for Final Divorce Void.
Movant Mary Ann Castro appeared in person and by attorneys ofrecord, Sarah Anne
Lishman and Jamie L. Graham, and announced ready.
Respondent Manuel G. Castro appeared in person and by attorney of record, Joseph
Appelt, and announced ready.
The Court finds that the "Agreement for Final Divorce" was orally pronounced and
rendered by Judge David A. Canalles on October 30, 2013. The Court further finds that the
"Agreement for Final Divorce" was approved by the bankruptcy court in Cause No. 12-52696 on
July 31, 2014, and THEREFORE ORDERS that the Motion to Declare Agreement for Final
Divorce Void is DENIED.
All relief not expressly granted is DENIED.
SIGNED ON
JUDGE LAURA SALINAS
Order on Motion toDeclare Agreementfor Final Divorce Void: Castro Page 1
12-52696-cag Doc#63 Filed 09/04/14 Entered 09/04/14 20:37:39 Main Document Pg 3 of 5
III. RELIEF FROM THE STAY
.9. Movant requests that this Honorable Court terminate the automatic stay provisions of tile Bankruptcy
Code to allow Movant to exercise all of its rights and remedies against the Debtor and Co-Debtor under state law,
including, inter alia, foreclosing its lien onthe Property.
10. Movant alleges that cause exists for the lifting of the stay__and Movant's interest is not adequately
protected. 11 U.S.C. § 362(d)( 1). The assessed value byAtascosa Cou
It has been necessary for Movant to hire the law firm ofCodilis &Stawiarski, P;C. to collect the debt
owed to it through this Court. Pursuant to the Note and Deed of Trust, Movant is entitled to reimbursement ofits
reasonable attorneys' fees for their services.
12. Movant requests that an Order granting its motion for relief from automatic stay and Co-Debtor Stay,
ifsttch Order should be entered, will be etfective immediately upon entry and. Rule 4001 (a) (3), is waived, and
enforcement ofsuch Order will not be stayed until the expiration offourteen days after entry ofthe Order.
13. Movant further requests that upon termination ofstay, it be exempt from further compliance with
FRBP 3002.1.
WHEREFORE, PREMISES CONSIDERED, Movant prays that this Court enter an Order granting relief
from the automatic stay to allow Movant to exercise and enforce all its rights and remedies against the Debtor and Co-
Debtor as a secured creditor and perfected lienholder to the Property; including, but not limited to, payments of
bankruptcy attorney lees and costs in the amount of S800.00, foreclosure and disposition of the Property, payment of
costs, expenses, and reasonable attorneys' fees inaccordance with the terms ofthe Note and Deed ofTrust and for such
other and further relief to which Movant may show itselfjustly entitled, either at law or in equity.
Respectfully submitted,
Codilis& Stawiarski,P.C.
By: Isl Angela K. Randermann
Angela ft. Randermann SBOT 24029787 (31688)
Yvonne V. Valdez SBOT 24069019
650 N. SamHouston Parkway East,Suite450
Houston, Texas 77060 (281) 925-5200
Facsimile: (281) 925-5300
ATTORNEYS FOR MOVANT
BUCKLEYH madole
Buckley Madole, P.C.
14841 Dallas Parkway, Suite 425
Dallas, TX 75254
Main: (972)643-6600
Fax: (972)643-6699
LEGAL PRECEDENT IS NOT CLEAR AS TO WHETHER THE SENDING OF THIS LETTER MAKES US
A DEBT COLLECTOR. TO THE EXTENT IT DOES, PLEASE BE ADVISED THAT THIS IS AN ATTEMPT
TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
HOWEVER, IF YOU ARE IN BANKRUPTCY OR HAVE BEEN DISCHARGED IN BANKRUPTCY, THIS
LETTER IS FOR INFORMATIONAL PURPOSES ONLY AND IS NOT INTENDED AS AN ATTEMPT TO
COLLECT A DEBT OR AS AN ACT TO COLLECT, ASSESS, OR RECOVER ALL OR ANY PORTION OF
THE DEBT FROM YOU PERSONALLY.
December 2,2014
MARY CASTRO
1501 OLIVE STREET
JOURDANTON, TX 78026
Re: Loan No.: 44675
Property: 1501 OLIVE STREET, JOURDANTON, TX 78026
FAIR DEBT COLLECTION PRACTICES ACT NOTD7ICATION
We represent BSIFinancial Services, Inc., whose address is 7505 Irvine Center Drive, Irvine, CA92618 which,.ifit is
not the Current Mortgagee, is acting as the Mortgage Servicer and representing the Current Mortgagee pursuant to a
Mortgage Servicing Agreement concerning the Note and Deed of Trust which are associated with the above referenced
ioannumber.
Our firm has been requestedto pursueforeclosure processingin accordance with the terms of the Note and Deed of Trust
and applicable law.
1. According to the information provided to us by ourclient, thetotal amount required to curethe default under the note
and deed oftrust through December 15, 2014 is $79,019.30 and the total amount required topayoff the debt through
November 30,2014 is $275,251.54.
2. Because ofpayment installments that accrue monthly and other charges that may vary from day to day, the total
amount required to cure thedefault may be greater on theday thatyou choose to pay. Likewise, because of interest
and/or other charges thatmay vary from day to day, thetotal amount required topayoffthedebt may begreater onthe
day that you choose to pay. Hence, should you choose topay either oftheamounts shown above, anadjustment may
be necessary after your check is received in which event we will notify you before the check is deposited for
collection. For further information, write our firm at Buckley Madole, P.C, Attn: Foreclosure Department, 14841
Dallas Parkway, Suite 425, Dallas, TX 75254 or call us at (972) 643-6600 .
3. You have thirty days afteryou receive this letter, to dispute the validity of the debt or any part of it. If you do not
dispute it within that period, our firm will presume that it is valid.
4. Ifyou notify ourfirm inwriting within thethirty-day period that thedebt, or any portion thereof, isdisputed, ourfirm
will obtain verification of the debt or a copy of ajudgment against you and a copy of such verification orjudgment
will be mailed to you by our firm.
Ifyou require further information, please let us hear from you.
Very truly yours,
i
Buckley Madole, P.C.
1io-3g?-(o13c1 314 S Franklin St / Second Floor
PO Box 517
Titusville PA 16354
BSI Financial 1-800-327-7861
814-217-1366 Fax
Services www.bsifinancial.com
April 27,2015
0iMi*>
rruJL/^
MANUEL G CASTRO JR
MARY ANN CASTRO
1501 OLIVE STREET x jT^O^A^
JOURDANTON, TX 78026
NOTICE OF SERVICING TRANSFER
Account #: 44675
The servicing of your mortgage loan is being transferred, effective May 15, 2015. This means that
after this date, a new servicer will be collecting your mortgage loan payments from you. Nothing else
about your mortgage loan will change.
BSI Financial Services is now collecting your payments. BSI Financial Services will stop accepting
payments received from you after May 14, 2015.
SN Servicing Corporation will collect your payments going forward. Your new servicer will start
accepting payments received from you on May 15, 2015.
Send all payments due on or after May 15, 2015 to SN Servicing Corporation at this address:
SN Servicing Corporation
• PO Box 602814
Charlotte, NC 28260-2814
Ifyou have any questions for either your present servicer, BSI Financial Services or your new servicer
SN Servicing Corporation about your mortgage loan or this transfer, please contact them using the
information below:
Current Servicer: New Servicer:
BSI Financial Services SN Servicing Corporation
Customer Care Customer Correspondence
314 S Franklin St, 2nd Floor 323 Fifth Street
Titusville, PA 16354 Eureka, CA 95501
1-800-327-7861 1-800-603-0836
Mon.-Fri. 8:00 a.m. - 11:00 p.m. EST Mon.-Fri. 8:00 a.m. - 5:00 p.m. PST
Saturday 8:00 a.m. - 12:00 p.m. EST
Licensed as Servis One, Inc. dba BSI Financial Services.
BSI Financial Services NMLS # 38078. Customer Care Hours: Mon. -Thurs. 8:00 am to 8:00 pm (ET), Fri. 8:00 am to 5:00 pm (ET), Sat. 8:00 am to 12:00 pm (ET).
Colorado Office Location: 13111 E. Briarwood Ave., Suite 340, Centennial, CO 80112 (303) 309-3839. Licensed as a Debt Collection Agency by the New York City
Department of Consumer Affairs,(# 2001485-DCA). North Carolina Collection Agency Permit (# 105608). Ifyou have
filed a bankruptcy petition and there is an "automatic stay" in effect in your bankruptcy case or you have received a discharge of your personal liability for the
obligation identified in this letter, we may not and do not intend to pursue collection of that obligation from you personally. Ifeither of these circumstances
apply,this notice is not and should not be construed to be a demand for payment from you personally. Unless the Bankruptcy Courthas ordered otherwise,
please also note that despite any such bankruptcy filing, whatever rights we hold in the property that secures the obligationremain unimpaired.
Page 1 of 2
NOTICE OF ACCELERATION AND NOTICE OF TRUSTEE'S SALE
DEED OF TRUST INFORMATION:
Date: 03/07/2006
Grantor(s): MANUEL G CASTRO JR, MARY ANN CASTRO
Original Mortgagee: WELLS FARGO BANK, N.A.
Original Principal: $191,250.00
Recording Information: Instrument 80487
Property County: Atascosa
Property: BEING A 9.45 ACRE TRACT SITUATED IN THE J. POITEVENT SURVEY,
ABSTRACT 1239, ATASCOSA COUNTY, TEXAS, AND BEING THAT SAME
9.45 ACRE TRACT AS CONVEYED BY THOMAS F. PERKS AND LOLA M.
PERKS TO MANUEL G. CASTRO AND MARY A. CASTRO RECORDED IN
VOLUME 152, PAGE 442, OFFICIAL PUBLIC RECORDS OF ATASCOSA
COUNTY, TEXAS; SAJD 9.45 ACRE TRACT SURVEYED BY JEFFREY B;
BERGER, R.P.L.S. NO. 5558 ON AUGUST 19, 2005 AND BEING MORE
PARTICULARLY DESCRIBED AS FOLLOWS:
BEGINNING AT A 1/2" STEEL ROD WITH A RED PLASTIC CAP STAMPED "RPLS 5558" ON THE NORTH
LINE OF COUNTY ROAD 438 (ALSO KNOWN AS OLIVE STREET) AT THE
SOUTHWEST CORNER OF THE REMAINING PORTION OF A 106.23 ACRE
TRACT AS RECORDED IN VOLUME 78, PAGE 430, DEED RECORDS OF
ATASCOSA COUNTY, TEXAS, FOR THE MOST SOUTHERLY SOUTHEAST
CORNER OF THE HEREIN DESCRIBED TRACT;
THENCE SOUTH 89 DEG 54" 00" WEST 509.51 FEET (BASIS OF BEARINGS) WITH SAID NORTH LINE OF
COUNTY ROAD 438 TO A STEEL FENCE CORNER POST AT THE MOST
SOUTHERLY SOUTHEAST CORNER OF THE EUGENE C. JUPE FAMILY
LIMITED TRACTS AS RECORDED IN VOLUME 251, PAGE 537 AND VOLUME
251, PAGE 543, OFFICIAL PUBLIC RECORDS OF ATASCOSA COUNTY,
TEXAS, FOR THE SOUTHWEST CORNER OF THE HEREIN DESCRIBED
TRACT;
THENCE NORTH 00 DEG 40" 00" WEST 405.38 FEET ALONG A WIRE FENCE WITH A COMMON LINE OF
SAID 9.45 ACRE TRACT AND SAID EUGENE C. JUPE FAMILY LIMITED
TRACTS TO A STEEL FENCE CORNER POST AT AN INTERIOR CORNER OF
SAID EUGENE C. JUPE FAMILY LIMITED TRACTS, FOR THE MOST
SOUTHERLY NORTHWEST CORNER OF THE HEREIN DESCRIBED TRACT;
THENCE ALONG A BARBED WIRE FENCE WITH THE COMMON LINES OF SAID 9.45 ACRE TRACT AND
SAID EUGENE C. JUPE FAMILY LIMITED TRACTS, NORTH 89 DEG 54' 00"
EAST 467.00 FEET TO A STEEL FENCE CORNER POST FOR AN INTERIOR
CORNER OF THE HEREIN DESCRIBED TRACT AND NORTH 00 DEG 40' 00"
WEST 467.00 FEET TO A STEEL FENCE CORNER POST TO A CORNER OF
SAID EUGENE C. JUPE FAMILY LIMITED TRACTS, FOR THE MOST
NORTHERLYNORTHWESTCORNEROF THE HEREIN DESCRIBEDTRACT;
THENCE SOUTH 89 DEG 54' 00" EAST 467.00 FEET ALONG A BARBED WIRE FENCE WITH THE
NORTHERNMOST NORTH LINE OF SAID 9.45 ACRE TRACT TO A STEEL
FENCE CORNER POST ON THE WEST LINE OF A 52.01 ACRE TRACT AND A
7.70 ACRE TRACT AS RECORDED IN VOLUME 303, PAGE 283, OFFICIAL
PUBLIC RECORDS OF ATASCOSA COUNTY, TEXAS, FOR THE NORTHEAST
CORNER OF THE HEREIN DESCRIBED TRACT;
i
THENCE SOUTH 00 DEG 40' 00" EAST 432.18 FEET ALONG A WIRE FENCE WITH THE COMMON LINE OF
SAID 9.45 ACRE TRACT, AND SAID 52.01 ACRE TRACT AND SAID 7.70 ACRE
TRACT TO A 1/2" STEEL ROD FOUND AT THE NORTH CORNER OF SAID
REMAINING PORTION OF 106.23 ACRE TRACT, FOR THE MOST
NORTHERLY, SOUTHEASTCORNEROF THE HEREIN DESCRIBEDTRACT;
THENCE ALONG A BARBED WIRE FENCE WITH THE COMMON LINES OF SAJD 9.45 ACRE TRACT AND
SAJD REMAINING PORTION OF 106.23 ACRE TRACT, SOUTH 89 DEG 54' 00"
WEST 415.69 FEET TO A 1/2" STEEL ROD FOUND AT THE NORTHWEST
CORNER OF SAJD REMAINING PORTION OF 106.23 ACRE TRACT, FOR AN
INTERIOR CORNER OF THE HEREIN DESCRIBED TRACT AND SOUTH 00
DEG 28' 41" WEST 440.20 FEET TO THE POINT OF BEGINNING AND
CONTAINrNG 9.45 ACRES OR 411,771 SQUARE FEET, MORE OR LESS.
Reported Address: 1501 OLIVE STREET, JOURDANTON, TX 78026
MORTGAGE SERVICING INFORMATION:
TheMortgage Servicer, it not the Current Mortgagee, is representing the Current Mortgagee pursuant to a
Mortgage Servicing Agreement.
Current Mortgagee: MLB SUB I, LLC
Mortgage Servicer: BSI Financial Services, Inc.
Current Beneficiary: MLB SUB I, LLC
Mortgage Servicer Address: 7505 Irvine Center Drive, Irvine, CA 92618
SALE INFORMATION
Date of Sale Tuesday, the 6th day of January, 2015
Time of Sale 12:00PM or within three hours thereafter.
Place of Sale AT THE WEST PORCH TO THE ATASCOSA COUNTY COURTHOUSE in
TXNOS Pg. 2 Matter: 9408-0016; 2146939188
Atascosa County, Texas, or, if the preceeding area is no longer the designated area, at
the area most recently designated by the Atascosa County Commissioner's Court.
Substitute Trustee(s): Troy Martin or Alexis Martin or Cassie Martin or Terri Martin or Melody Speer,
Cristina Camarata, Sammy Hooda, Michael Burns, Alexander Wolfe, Suzanne Suarez
or Adam Womack, any to act
Substitute Trustee Address: 14841 Dallas Parkway, Suite 425, Dallas, TX 75254
WHEREAS, the above-named Grantor previously conveyed the above described property in trust to secure
payment of the Note set forth in the above-described Deed of Trust; and
WHEREAS, a default under the Note and Deed of Trust was declared; such default was reported to not have
been cured; and all sums secured by such Deed of Trust were declared to be immediately due and payable; and
WHEREAS, the original Trustee and any previously appointed Substitute Trustee has been removed and Troy
Martin or Alexis Martin or Cassie Martin or Terri Martin or Melody Speer, Cristina Camarata, Sammy Hooda,
Michael Bums, Alexander Wolfe, Suzanne Suarez or Adam Womack, any to act, have been appointed as Substitute
Trustees and requested to sell the Property to satisfy the indebtedness; and
WHEREAS, the undersigned law firm has been requested to provide these notices on behalf of the Current
Mortgagee, Mortgage Servicer and Substitute Trustees;
NOW, THEREFORE, NOTICE IS HEREBY GIVEN of the foregoing matters and that:
1. The maturity of the Note has been accelerated and all sums secured by the Deed of Trust have been declared to be
immediately due and payable.
2. Troy Martin or AlexisMartin or CassieMartin or Terri Martin or Melody Speer,Cristina Camarata, Sammy
Hooda, Michael Bums, Alexander Wolfe, Suzanne Suarez or Adam Womack, any to act, as Substitute Trustee will
sell the Property to the highest bidder for cash on the date, at the place, and no earlier than the time set forth above
in the Sale Information section of this notice. The sale will begin within three hours after that time.
3. This sale shall be subject to any legal impediments to the sale of the Property and to any exceptions referenced in
the Deed of Trust or appearing of recordto the extentthe same-are still in effectand shall not cover any property
that has been released from the lien of the Deed of Trust.
4. No warranties, express or implied, including but not limited to the implied warranties of merchantability and
fitness for a particular purpose shall be conveyed at thesale, save andexcept the Grantor's warranties specifically
authorized by the Grantor in the Deed of Trust. The property shall be offered "AS-IS", purchasers willbuy the
property "atthepurchaser's own risk" and "athisperil", and norepresentation is made concerning thequality or
nature of titleto be acquired. Purchasers will receive whatever interest Grantor andGrantor's assigns have in the
property, subject to any liens or interests ofany kind that may survive thesale. Interested persons are encouraged
to consult counsel of theirchoice priorto participating in the saleof the property.
Very truly yours,
Buckley Madole, P.C.
TXNOS Pg:3 Matter: 9408-0016; 2146939188
June 2,2015
To: SN SERVICING CORPORATION
323 5th STREET
EUREKA CA 95501
FROM:
Maryann Castro
1501 Olive
Jourdanton Texas 78026
Re: New Loan Number 0000261440
Old Loan Number 44675
Collateral 1501 OLIVE STREET, JOURDANTON TEXAS 78026
Dear: SIR/ MAM NOTICE OF DISPUTE
The following problem have occurred in reference to this property you purchased below property value
and the two Servicers Wells Fargo Home Mortgage, BSI Financial TOOK part in Mortgage fraud and this
has been reported to the Attorney General Of Texas, and the homeowners principle residence Maryann
Castro submitted two request the following were submitted a loan Modification and a harp application
her request were not denied nor were they approved she never received a response and had to retain
an Attorney in Jan 1,2015 to stop foreclosure .And it was stopped and the Mortgage Servicer BSI
FINANCIAL did not offer a modification wanted 45,000 to settle the property value is 125,000 and the
land is 54,000 see copy of Certified Appraisal.
Maryann Castro was awarded the property 1501 Olive on Oct 30,2013 while Wells Fargo held the note
and made many promises saying the Modification was in process when it never was Manuel Castro held
the note at that time and Wells Fargo never made any attempt to process the Modification knowing
there was a hardship at that time Manuel Castro and Maryann Castro were in process of Divorce and
Manuel Castro was to make Mortgage Payments and did not he filed Bankruptcy and did not tell
Maryann Castro at that time her name was on the Deed Only see the name of the Borrower it says
Manuel Castro.
Upon final Divorce Maryann Castro did not know Manuel Castro had not made any Mortgage payments
and had the home Mortgage in Bankruptcy Protection and owed a balance there is no final Divorce
SN Servicing request Making Home Affordable
Decree Filed yet. Upon Oct 30,2013 Wells Fargo sold the Note to BSI Financial and this Account was in
Active Bankruptcy and Arrears were being deducted weekly from Manuel Castro paycheck see
bankruptcy statement BSI Financial put the Debt of Arrears in Maryann Castro name and did not have
permission did not notify her they received a copy of the Divorce Decree it was to show she was
awarded the Home 1501 Olive not the Debt. The fraud that was committed by BSI Financial has been
reported to the Attorney General Office and to the Court Of Appeals in San Antonio Texas.
Maryann Castro has made many Attempts to Contact BSI Financial to request a loan modification a harp
application and sent it via certified mail and nothing was ever processed and this note was in litigation
again now a New Servicer SN Servicing purchase this note below appraisal value attempting to collect
what the following Banks have sold below cost in Attempt to collect money causing the high balance on
this account for failure to process a loan Modification and putting the unpaid debt Manuel Castro did
not pay now remember the Loan was in his name through Wells Fargo then BSI Fraudly put the Debt in
Maryann Castro name when she didn't sign the Loan Mortgage due to her disability see copy BSI Put the
Debt in Maryann Castro name because of the Document a handwritten Statement showing home 1501
Olivewas Awarded to her on Oct 30,2013 Maryann Castro attempt was to process a Making Home
Affordable Modification or Harp Due to Divorce Medical Job Loss. Instead the BSI Servicer applied the
Debt in Maryann Castro name when she didn't sign the Home Mortgage loan on this Account when it
was Granted and that is Fraud it has been reported to the Better Business Bureau and Attorney General
of Texas And she has also Retained Attorney Matthew Obremier of San Antonio Now before it goes any
further Maryann Castro is sending again request of A Modification Making Home Affordable (MHA) This
was a Fannie Mae account when Wells Fargo granted the Loan a fixed rate and the payments were
1789.00 that is too high Maryann Castro needs the Servicer to process a Modification at 2.4% interest a
30 or even 40 year note and eliminate the high overcharged fees that were applied prior to the new
purchaser SN Servicing Corporation accepted not knowing the Actual truth of the account purchase
below the value and expect to collect not knowing the Actual facts and lower the house payment at
867.69 monthly.
The Servicer Wells Fargo BSI AND prior Owner Manuel G. Castro JR. did not pay the property taxes 2013
and did not insure the home Mortgage property Maryann Castro when she retained the property did
not know this and has kept up with Making Sure the Collateral has Home Owners insurance see Policy
and taxes are being paid see Balance 2013 were in default and the tax collector wanted to enforce and
order and Maryann Castro stopped it by payingthe past due balance Monthly there is still a balance of
725.00 see copy of Tax statement.
A copy of this Letter is going to the Following persons
Appeals Court in San Antonio Texas
Attorney Matthew Obremier
Credit Bureau
Attorney General of Texas
Maryann Castro is seeking a Making Home Affordable Modification
Home Affordable Unemployment Programs
SN Servicing request Making Home Affordable
Home Affordable Foreclosures Alternative,
Harp Application due to Divorce, Medical, Job Loss.
Affordable Mortgage Payments Relief
1501 Olive is Maryann Castro primary residence when she retained ownership through Divorce she did
not know the status of the Account the prior owner had it and had defaulted. Please assist in processing
her Request to avoid anymore unneeded unwanted overcharge fees and Attorney fees as she was never
provided the Service she applied for to making the Home Affordable.
Respectfully
Maryann Castro
Copy of letter sent Attorney Matthew Obermeier, Appeals Court Of San Antonio
Matthew Obermeier
14255 Blanco Rd
San Antonio Texas 78216
210-296-5828
Ho
SN Servicing request Making Home Affordable
a Complete items 1.2, and 3. Also complete
item 4 if Restricted Delivery isdesired.
mPrint your name and address on the reverse
so that we can returnthe card to you.
a Attach this card tothe back of themailpiece,
oron the front if space permits. raddfeidfffe^tfr^iteml^ •''W
,1. Article Addressed to: ^ nter delivery address below:
If YES, enter O N/
Shi S"€ruiClI'V'V 2Q15
3. Service Type
D Certified Mail® • Priority Mail Express™
• Return Receipt forMerchandise
Q560! O Registered
• Insured Mail • Collect on Delivery
4. Restricted Delivery? (Extra Fee) • Yes
2. Article Number
(Transfer from service label
7D14 34^0 DDDD ^237 135b [
PS Form 3811, July 2013 Domestic Return Receipt
us Complete items1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
Printyour name and address on the reverse
so that we can return the card to you.
Attachthis card to the back of the mailpiece,
or on the front if space permits. '
D. Is delivery address different from item 1? • Yes
1. Article Addressed
5bCU to:
l\J. u If YES, enter delivery address below: d No
11 r
f^ic ->Md' ^1 Cp.uH
,^OZ.to^W 3. Service Type
• Certified Mail® • Priority Mail Express™
E>A Wo nKDuOytf Ufr • Registered
• Insured Mail
• Return Receipt for Merchandise
• Collect onDelivery '
'*& no?n. 4. Restricted Delivery? (Extra Fee) • Yes
2. Article Number
(Transfer from service label)
7014 34=10 DDDD ^£3?" 13b3
PS Form 3811, July 2013 Domestic Return Receipt
BUCKLEY • MADOLE
Buckley Madole, P.C.
14841 Dallas Parkway, Suite 425
Dallas, TX 75254
Main: (972)643-6600
Fax: (972)643-6699
LEGAL PRECEDENT IS NOT CLEAR AS TO WHETHER THE SENDING OF THIS LETTER MAKES US
A DEBT COLLECTOR. TO THE EXTENT IT DOES, PLEASE BE ADVISED THAT THIS IS AN ATTEMPT
TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WHX BE USED FOR THAT PURPOSE.
HOWEVER, W YOU ARE IN BANKRUPTCY OR HAVE BEEN DISCHARGED IN BANKRUPTCY, THIS
LETTER IS FOR INFORMATIONAL PURPOSES ONLY AND IS NOT INTENDED AS AN ATTEMPT TO
COLLECT A DEBT OR AS AN ACT TO COLLECT, ASSESS, OR RECOVER ALL OR ANY PORTION OF
THE DEBT FROM YOU PERSONALLY.
December 2,2014
MARY CASTRO
1501 OLIVE STREET
JOURDANTON, TX 78026
Re: Loan No.: 44675
Property: 1501 OLIVE STREET, JOURDANTON, TX 78026
FAm DEBT COLLECTION PRACTICES ACT NOTD7ICATION
We represent BSI Financial Services, Inc., whose address is 7505 Irvine Center Drive, Irvine, CA 92618 which, ifitis
not the Current Mortgagee, is acting as the Mortgage Servicer and representing the Current Mortgagee pursuant to a
Mortgage Servicing Agreement concerning the Note and Deed of Trust which are associated with the above referenced
ioan number.
Ourfirm has beenrequested to pursueforeclosure processing in accordance with the terms of the Note and Deed of Trust
and applicable law.
1. According to the information provided to usbyourclient, thetotal amount required to cure thedefault under thenote
and deed oftrust through December 15, 2014 is$79,019.30 and the total amount required topayoff the debt through
November 30,2014 is $275,251.54.
2. Because ofpayment installments that accrue monthly and other charges that may vary from day to day, the total
amount required to cure the default may be greater on the day thatyou choose to pay. Likewise, because of interest
and/or other charges that may vary from day to day, thetotal amount required topayoffthedebt may begreater onthe
day that you choose topay. Hence, should you choose to pay either ofthe amounts shown above, anadjustment may
be necessary after your check is received in which event we will notify you before the check is deposited for
collection. For further information, write our firm at Buckley Madole, P.C, Attn: Foreclosure Department, 14841
Dallas Parkway, Suite 425, Dallas, TX 75254 or call us at (972) 643-6600 .
3. You have thirty days after you receive this letter to dispute the validity of the debt or any part of it. If you do not
dispute it within that period, our firm will presumethat it is valid.
4. Ifyou notify our firm inwriting within the thirty-day period that the debt, orany portion thereof, is disputed, our firm
will obtain verification ofthe debt or a copy ofajudgment against you and a copy of such verification orjudgment
will be mailed to you by our firm.
If you require further information,please let us hear from you.
Very truly yours,
Buckley Madole, P.C.
ACCEPTEC
041400785CV
FOURTH COURT OF APPEAL
SAN ANTONIO, TEXAS
1/9/2015 3:02:21 PM
KEITH HOTTLl
CLERK
COURT OF APPEALS NO. 04-14-00785-CV
TRIAL COURT CASE NO. 2011 CI 15957
IN THE MATTER OF § IN THE DISTWCT4G<&#fOFAPPEALS
THE MARRIAGE OF § SAN ANTONIO, TEXAS
§ 01/9/2015 3:02:21 PM
MANUEL G. CASTRO § 45th JUDICIAL DISTUaOTE. HOTTLE
AND § Clerk
MARY ANN CASTRO § BEXAR COUNTY, TEXAS
RESPONSE TO APPELLANT'S AFFIDAVIT OF INDIGENCY
This Response is brought by Appellee, MANUEL G. CASTRO, by and through his attorney,
JOSEPH P. APPELT, who shows in support thereof:
1. On or about December 29,2014 Appellant filed certain documents, including an
Affidavit ofIndigency in this matter;
2. Appellee contests thevalidity of saidaffidavit based on several facts that have come to
light during the course of thematter in District Court;
3. First, Appellant asserts in hersworn affidavit thatheronly source of income is herSocial
Security disability check in the amount of $788.00 permonth. This is a false statement forthe
following reasons:
a. Appellant, Mary Ann Castro, has a catering business "Catering by Mary Ann" as
evidenced by the advertisement attached hereto as exhibit "A"
b. Appellant has stated in court that she makes "$15 an hour," evidenced by her
statement on line 15 of page7 of the certified transcript attached hereto as Exhibit
"B"
4. In addition, Appellee further objects tothe validity ofAppellant's affidavit inthat she is
currently the owner ofa 2013 Chevrolet Cruz automobile; evidencing her income isgreater than
only the $788.00 monthly Social Security check she swore to inthe said affidavit;
. 5. Also, Appellant files heraffidavit in support ofother filings indicating she does not have
thefinancial resources to payhercosts or hire an attorney. Appellant has made this same
j assertions throughout the case at the District Court level yet she has retained the
following attorneys in conjunction with her case:
a. Edward Piker J
b. Rebecca C. Martinez (now a Justice on the 4,h Court ofAppeals)
|..i."'P0 >
ROOM 101 >P.
4100 S NEW BRAUNFELS ^ ^S^TX
&/L/^y ^\
We will process your application for Supplemental Security Income as quickly as
possible. You should hear from us within J PO days. If you do not hear from
us by then, please get in touch with us.
We will let you know if we need more information to decide if you are eligible
for SSI payments. In the meantime, if you move or change your mailing address,
you--or someone for you-- should report the change to the office shown abovlT.
Also, you (or someone for you) must let us know if you are admitted to a
hospital or other medical facility. You could lose some SSI payments if you do
not let us know right away.
Always give your Social Security" number when writing" or telephoning-about "your"
claim. If you have any questions about your claim, we will be glad to help you.
MARYANN CASTRO _. ~ —
919 SUTTON APT 22
SAN ANTONIO, TX 78228
!>*#" ?•
Your New Benefit Amount 15o4494
BENEFICIARY'S NAME: MARYANN CASTRO
.Your Social Seciirilybenefits will iacrease;by 1J:percent In2015 because ofarise mthecost of
li%isg. Ybu can ase this 1^
rent, or energy assistance; bank loans; or for other business. Keep this letter with your
important financial records.
How Much Will I Get And When?
8Your monthly amount (before deductions) is $1,148.90,
• The amount we deduct for Medicare medical insurance is $104.90.
z3S ±HOa^h Fndaj Recorded information and services a" «^»sx~*.*-- =. .- -j
^busiest early in the week, early in the month, as well as during the week between Christmas
and NewYear's Day; it is best to call at other times. Ifyou are deaforhard ofhearmg, caM our
TTY number 1-800-325*0778. Ifyou are outside the United States, you can comaet_anyX ._-
Embassy or consulate office. Please have your Social Security claim number ava^wJ.^l
Mining Group Inc. Advice Routing: Pay Grpup: SUM-Hourly Cra;
Opportunity Employer Dept: 14965 - San Miguel Labor Pay Begin Date: 04/01/2013
:31096 Sub Payroll: 3 Pay End Date: 04/07/2013
fE 68131 402/342-2052 Pay Basis: Hourly
ruadalup« Castro Jr LAST JOB WORKED: >TAX DATA:, Federal
:kory Shadow Empl #: 00000 Marital Status: Marriec
fTX 78112 Job#: 14965 Allowances: 0
Location: San Miguel Labor Addl. Pet.:
247763 Addl. Amt.:
liiM?i^i:i;iai^6Ja^ta
Current YTD
n Rate Hours Earnings Hours Earnings Description^
20.710000 40.00 828.41 52350 10324.70 Fed Wlthholdng
- Time and One H 31.065000 18.00 559.17 147.00 456238 Fed MED/EE
ay 23.00 47139 Fed OASDI/EE
Off 4350 900.90
n Non-Taxable 324.83
58.00 138758 737.00 17,08420 Total:
s^ijiiiiii^ W^m^mmM^im
n Current YTD Description Current YTD Description
lsurance 5459 77150 Employee Supplemental Lif 5.10 7650 Medical Insurance
urance 527 78.14 Accident Death & Dismbr - 030 450 Vision Insurance
Depend AD & D - KieChoice 0.18 2.70 Group Term Life Insuram
Clothing 4.15 6025 Group Term Life Insuram
Garnishment - Bankruptcy 184.62 2,76930 Disability Insurance
59.86 849.64 I Total: 19435 251325 L* Taxable" ````"
138758 1329.00 259.91 25421
17,08420 15,928.86
E: Advice #53850
Total: *
1
2 REPORTER'S RECORD
3 VOLUME 1 OF 1 VOLUME
4 TRIAL COURT CAUSE NO. 2011-CI-15957
5 MANUEL G. CASTRO ) IN THE DISTRICT COURT
)
6 VS.
) 45TH JUDICIAL DISTRICT
)
7 MARY A. CASTRO ) BEXAR COUNTY, TEXAS
8
9
10
11 HEARING
12 DECEMBER 29, 2014
13
14 On the 29th day of December 2014, the following
15 proceedings came on to be heard in the above-entitled and
16 numbered cause before the HONORABLE BARBARA NELLERMOE, Judge
17 Presiding, held in 45th District Court, Sah Antonio, Bexar
18 County, Texas:
19
Proceedings reported by machine shorthand.
20
21
22
i -.r
23
24
25
JUDITH A. STEWART, C.S.R.
45TH DISTRICT COURT
/
interest, and claim in and to that property:
H-l. All household furniture, furnishings, fixtures, goods* art objects, collectibles,
appliances, and equipment in the possession of the husband or subject to his sole control.
H-2. All clothing, jewelry, and other personal effects in the possession of the husband
or subject to his sole control,
H-3. All sums of cash in the possession of the husband or subject to his sole control,
including funds on deposit, together with accrued but unpaid interest, in banks, savings
institutions, or other financial institutions, which accounts stand in the husband's sole name or
from which the husband has the sole right to withdraw funds or which are subject to the
husband's sole control.
H-4. All sums, whether matured or unmatured, accrued or unaccrued, vested or
otherwise, together with all increases thereof, the proceeds therefrom, and any other rights
related to any profit-sharing plan, retirement plan, Keogh plan, pensionjlari, employee stock
— . f
option plan, 401 (k) plan, employee savings plan, accrued unpaid bonuses,, disability plan, or f
— O ^iE. do ^o""g-4"
other benefits existing by reason ofthe riusbandVpast, present, or future employme&tJ /\ qa Lp^ /V1 0 rjr
H-5. All individual retirement accounts, simplified employee pensions, annuities, and'p- J
variable annuity life insurance benefits in the husband's name.
H-6. The 1999 Subaru motor vehicle, together with all prepaid insurance, keys, mid
title documents. ~^ U"^&Pt ^Jjfch ft^c/o^/^ ,
ED AND DECREED that the wife, MARY ANN CASTRO, is awarded the
•/-• s •—~ "V
'tnd separate property, anc| the husband isdivested ofall right, title, interest,
Jt property:
same date, butsigned on £Xco l>*« ^f '3- list " s juVV , u " fi" V "^'"a^xN'
I *^K 1 * t..
*%
r ^ f
h1^s://mail.googlexom/Jscs/mail-sMic/Jjs/k=gmail.main.en.HGrFWflRUk.O/m==m 1/2/2014
GREEN TREE SERVICING LLC
1-800-643-0202
345 SAINT PETER STREET L1000 99C
SAINT PAUL, MN 55102
+ 0533173 000021017 01GT1C 0137107 D12S201S
MARY ANN CASTRO
PO BOX 495 •
PLEASANTON TX 78064-0495
!'i'»iilli>l{i>ll'iilr'li>illllgll!'ll'Pi|ililll"ii !•"
•••!•*_ " J. 1 A i rI i % m I fl
SC0104-000
I1 . » n.1
AI 'It it*'
Instructions for Debtor
You received this form because a Federal Government agency or an applicable Box 4. Shows a description of the debt. If box 7 is completed, box 4 also
financial entity (a creditor) has discharged (canceled or forgiven) a debt you shows a description of the property.
owed, or because an identifiable event has occurred that either is or Is deemed
to be a discharge of a debt of S600 or more. If a creditor has discharged a debt Box 5. Shows whether you were personally liable for repayment of the debt
you owed, you are required to include the discharged amount in your income, when the debt was created or, if modified, at the time of the last modification.
even if it is less than S600, on the "Other income* line of your Form 1040. See Pub. 4681 for reporting instructions.
However, you may not have to include all of the canceled debt in your income.
There are exceptions and exclusions, such as bankruptcy and insolvency. See Box 6. Shows the reason your creditor has filed this form. The codes in this
Pub. 4681, available at IRS.gov, for more details. If an identifiable event has box are described in more detail in Pub. 4681. A—Bankruptcy; B—Other
occurred but the debt has not actually been discharged, then include any judicial debt relief; C—Statute of limitations or expiration of deficiency period;
discharged debt in your income in the year that it is actually discharged, unless D—Foreclosure election; E—Debt relief from probate or similar proceeding;
an exception or exclusion applies to you in that year. F—By agreement; G—Decision or policy to discontinue collection;
H—Expiration of nonpayment testing period; or I—Other actual discharge
Debtor's identification number. For your protection, this form may show only
before identifiable event.
the last four digits of your social security number (SSN), individual taxpayer
identification number (ITIN), or adoption taxpayer identification number (ATIN).
However, the creditor has reported your complete identification number to the Box 7. If, in the same calendar year, a foreclosure or abandonment of property
IRS and, where applicable, to state and/or local governments. occurred in connection with the cancellation of the debt, the fair market value
(FMV) of the property will be shown, or you will receive a separate Form
Account number. May show an account or other unique number the creditor 1099-A. Generally, the gross foreclosure bid price is considered to be the FMV.
assigned to distinguish your account. For an abandonment or voluntary conveyance in lieu of foreclosure, the FMV
is generally the appraised value of the property. You may have income or loss
Box 1. Shows the date the earliest identifiable event occurred or, at the because of the acquisition or abandonment. See Pub. 4681 for information
creditor's discretion, the date of an actual discharge that occurred before an about foreclosures and abandonments. If the property was your main home,
identifiable event. See the code in box 6. see Pub. 523 to figure any taxable gain or ordinary income.
Box 2. Shows the amount of debt either actually or deemed discharged. Note. Future developments. For the latest information about developments related
If you do not agree with the amount, contact your creditor. to Form 1099-C and its instructions, such as legislation enacted after they
were published, go to www.irs.gov/form1099c.
Box 3. Shows interest if included in the debt reported in box 2. See Pub. 4681
to see if vou must include the interest in gross income.
• CORRECTED (if checked)
CREDITOR'S name, street address, city or town, state or province, country, ZIP or OMB No. 1545-1424
foreign postal code, and telephone no.
GREEN TREE SERVICING LLC Cancellation
345 SAINT PETER STREET L1000 99C
SAINT PAUL, MN 55102
»®14 of Debt
1-800-643-0202
Form 1099-C
CREDITOR'S Federal identification number DEBTOR'S identification number 1 Date of identifiable event 2 Amount of debt discharged
XX-XXXXXXX XXX-XX-5895 02/04/2014 11,792.97 Copy B
$ For Debtor
DEBTOR'S name, street address (including apt. no.l, city or town, state or province, 3 Interest if included in box 2 4J Debt description This is important tax
country, and ZIP or foreign postal code information and is being
furnished to the Internal
Mortgage Loan Revenue Service. If you
$ are required to file a
5 If checked, the debtor was personally liable for repayment of the return, a negligence
MARY ANN CASTRO
penalty or other
PO BOX 495 debt *• fXl
sanction may be
PLEASANTON TX 78064-0495 imposed on you if
taxable income results
6 Identifiable event code 7 Fair market value of property from this transaction
A and the IRS determines
that it has not been
Account number (see instructions)
reported.
27502923
Form 1099-C (Keep for your records.] www.irs.gov/form1099c Department of the Treasury - Internal Revenue Service
Green Tree Servicing LLC QCQQt\ VtQ&
Document Custody - T313
7360 S. Kyrene Rd.
Tcmpe,AZ 85283
1-888-315-8733
Fax 1-888-221-7381
GTServiflflg.CQin
February 13,2014
HIGIER, ALLEN AND LAUTCN
ATTN:RICRABD MCKJNNEY
5057 KELLER SPRINGS RD.,STE600
ADDISON, TX 75001
RE: Account Number 27502923*;
Dear StR OR MADAM;
Our records indicate the above-referenced account with Green Tree ServicingLLC* ("Green
.Tree") has been settled infill. Enclosed are certain original documents you should retain for your
records in connection with your account.
Ifyou have any questions regarding this account, please contact our Document Custody department at
1-888-315-8733 ext. 33705.
Sincerely,
Green Tree
•Green Tree Servicing LLC and related entities, including, for certain loans, in Alabama, Green
Tree-AL LLC; in Minnesota, Green Tree Loan Company; and in Pennsylvania, Green Tree
Consumer Discount Company.
Account S«tted-iii-Full-Borrower Ddcs 03-0M0 LTR-551
Statement of Account
NOTICE: This is a statement of Taxes Due as of 06/01/2015 12:26:41PM
based upon the tax records of the tax office.
ATASCOSA COUNTY TAX OFFICE , . • - vr'Vs-;) ;:Property Information
1001 OAK STREET Property ID: 65922 'Geo ID: 00769-00-000-000505
JOURDANTON, TX 78026 Legal Acres: 0.0000
Legal Desc: IMPROVEMENT ONLY, LABEL #TEX0561908, LOC ON :
PID 58181
Situs: 1965PATTON RD ,
DBA:
Exemptions; . \_.
Owner ID: 145456 Ownership: 100.00%
CASTRO MANUEL & MARY ANN Value Information
% MICHAEL & MISTY HERNANDEZ Improvement HS: 19,910
7815 E 3RD ST Improvement NHS: 0
Land HS: 0
SOMERSET, TX 78069 Land NHS: 0
Productivity Market: 0
.Productivity Use: 0
Assessed Value 19,910
Entity. Description -..•'. '•'V '' '"' • : Pet. sExCode'ji-frJv Description'??-
FMLR ' FARM TO MARKET ROAD 100.00%
GAT ATASCOSA COUNTY 100.00%
SPO POTEETISD 100.00%
WEV EVERGREEN WATER DIST 100.00%
Unpaid Bills Summary
Entity Year Statement ID Tax Rate Type 'v-TaxDue Disc/P&l Attorney Feesn. Total Due
FMLR 2013 53837 0.076000 L ' 9.94 2.88 1.92 14.74
GAT 2013 53837 0.340600 L 44.55 12.91 8.62 66.08
SPO 2013 53837 1.419000 L 185.59 53.82 35.91 275.32
WEV 2013 53837 0.006000 L 0.78 0.22 0.15 1.15
Total for Year 2013 240.86 69.83 46.60 357.29
Total For All Years 240.86 69.83 46.60 357.29
Total Due if Paid By 06/30/2015 357.29
Paid Refunds Summary , , ';:
Entity' Year' Statement ID < "* < Date Refunded; ^Refund Amount Raid
Total For Year 2013 0.00
FMLR 2009 6439 01/07/2010 0.70
GAT 2009 6439 01/07/2010 3.11
SPO 2009 6439 01/07/2010 6.13
WEV 2009 6439 01/07/2010 0.06
Total For Year 2009 10.00
Total Refunds Paid 10.00
*** End of Statement "*
NOTICE: This document is not a tax certificate and does not absolve a Taxpayer from tax liability in any way. If this document is found to be Page 1
in error, it may be corrected by the Collection Officelisted above. Responsibility to pay the remaining taxes rests entirely with the Taxpayer,
True Automation. Inc.
as outlined in the Texas Property Tax Code.
J&Jr.JPG Page 1 of1
i)fV'%
. ' .I**"fa.
1* V «Jw
f <* I
I
I.
i» II
v^v
f£
https://mail.google.com/J'scs/mail-s" 1/2/2014
To; Michael and Misty Hernandez
7815 E 3RD St
Somerset Texas 78069
From;
Maryann Castro
1501 Olive
Jourdanton Texas 78026
Enclosed is the contract you signed and attempted fraud by not communicating with Maryann Castro
who did not surrender her interest.
You owe a-te fees, interest, taxes and have not made one payment on or about July 2011 and conspired
to own a asset that you have not paid off the agreement signed by you see copy.
Maryann Castro will accept a reasonable offer in the amount of 15,000 the balance owed to Maryann
Castro is
2011 Aug,St,Oct,Nov,Dec with late fee =2750
2012 Jan-Dec No payments and late fee added 6600 rs
201.3 Jan-Dec No Payments and late fee added 6600
2014 Jan- Dec No payments and late fee added 6600
2015 no payment made or taxes paid and late fee 3300
Unpaid taxes 357-29
The.agreement is void and right to repossession until payment is made in full the agreement is valid and
it was not given to you the 95 fleetwood Itried working it out with you and you threatened me. I am in
my right to reposes and you agreed to pay and pay the terms ignoring this will not make it go away.
Total due-26,207.29-7000 you paid Greentree Servicer the title is not released to you due to
non-payment total due as of 6/1/2015 is 19,207.29 Maryann Castro will settle for 15,000.
Copy sent on 6/1/2015 this is a legal matter and needs to be settled the servicer was paid and you
disregarded the contract with the attempt to steal an asset not awarded to you and debt not paid to
Maryann Castro see contract Manuel Castro surrendered his interest and the debt is to be paid to
Maryann Castro you have 30 days to respond and payVrepossession will take place by law I am in the
right the contract was never paid in full. Your Attorney did not clear you from paying me the outstanding
balance. Please remit payment or surrender the 95 fleetwood you signed you will return if you do not
pay and you have not attempted any communication or payment. >
Respectfully
Maryann Castro
1501 Olive
Jourdanton Texas 78026
Date 6/1/2015
ff /A
NOTICE: This is a statement of Taxes Due as of 06/01/2015 12:26:41PM
based upon the tax records of the tax office.
ATASCOSA COUNTY TAX OFFICE Property Information
1,001 OAK STREET Property ID: 65922 Geo ID: 00769-00-000-000505
JOURDANTON, TX 78026 Legal Acres: 0.0000
Legal Desc: IMPROVEMENT ONLY, LABEL #TEX056'1908, LOC ON
PID 58181
Situs: 1965PATTON RD ,
DBA:
Exemptions: i
Owner ID: 145456 Ownership: 100.00%
CASTRO MANUEL & MARYANN Value Information
% MICHAEL & MISTY HERNANDEZ Improvement HS: 19,910
7815 E 3RD ST • Improvement NHS: 0
Land HS: 0
SOMERSET, TX 78069 Land NHS: 0
Productivity Market: 0
Productivity Use: 0
Assessed Value 19,910
Entity Description Pet. Ex Code Description
FMLR FARM TO MARKET ROAD 100.00%
GAT ATASCOSA COUNTY 100.00%
SPO POTEET ISD 100.00%
WEV EVERGREEN WATER DIST 100.00%
Unpaid Bills Summary
Entity Year Statement ID Tax Rate Type Tax Due Disc/P&l Attorney Fees Total Due
FMLR 2013 53837 0.076000 L 9.94 2.88 1.92 14.74
GAT 2013 53837 0.340600 L 44.55 12.91 8.62 66.08
SPO 2013 53837 1.419000 L 185.59 53.82 35.91 275.32
WEV 2013 53837 0.006000 L 0.78 0.22 on 5 1.15
Total for Year 2013 240.86 69.83 46.60 357.29
Total For Ail Years 240.86 69.83 46.60 357.29
Total Due if Paid By 06/30/2015 357.29
Paid Refunds Summary
Entity Year Statement ID Date Refunded Refund Amount Paid
Total For Year 2013 0.00
FMLR 2009 6439 01/07/2010 0.70
GAT 2009 6439 01/07/2010 3.11
SPO 2009 6439 01/07/2010 6.13
WEV 2009 6439 01/07/2010 0.06
Total For Year 2009 10.00
Total Refunds Paid 10.00
*** End of Statement ***
NOTICE: This document is not a tax certificate and does not absolve a Taxpayer from tax liability in any way. If this document is found to be Page 1
in error, it may be corrected by the Collection Office listed above. Responsibility to pay the remaining taices rests entirely with the Taxpayer,
Tfu« Automation, Inc.
as outlined in the Texas Property Tax Code.
•* i
fS^T -• > *'t f "-; 'f- ^ify
"t n* ",**« -''"'" -*
it
5? si1 (. f! ».
-All
James E. Dickson Jr., M.D.
Diplomate American Board of Psychiatry and Neurology
14815 San Pedro Ave.
San Antonio, Texas 78232
Phone: (210)494-1991
Fax: (210)494-7575
January 31, 2013
To Whom it May Concern:
This is to confirm that Mary Ann Castro has been a patient of mine beginning with her initial
evaluation with me on 3/2/01. She has past psychiatric diagnoses of Major Depression, and
Panic Disorder. In addition she also exhibited some symptoms consistent with Attention
Deficit Disorder. She was last seen by me on .12/21/11.
Sincerely,
James Dickson Jr., M.D.
Silvester Foot Clinic
409 N. Bryant
Pleasanton, TX 78064
(830)569- 3338
FAX (830)569- 6833
Patient: CASTRO, MARYANN, DOB: 09/23/1965, Age: 49 years, Female
Acct #: 4320
CHART SUMMARY
Name: CASTRO, MARYANN Acct# 4320
1501 OLIVE Date of Birth: 09/23/1965
JOURDANTON, TX Gender: Female
78026
Work Phone: None Home Phone: (830)496-0133
Cell Phone: None Email:
Marital Status: Spouse/Partner:
Primary Ins: MEDICARE DC TEXAS Secondary Ins: BLUE CROSS BLUE
SHIELD
Last Plan Note: 06/09/2015
Order bone stimulator and Subtalar joint immobilizing AFO (Arizona).
Patient was scheduled for casting of the AFO.
The patient was requesting an additional injection but I explained that steroid injections can delay the
bone healing that should normally occur and I do not want to do that.
I also discussed the possibility of percutaneous surgery which would involve injecting the sinus where the
screw was removed with some type of bone morphogenic protein or osteogenic gel, and percutaneous
screw fixation of the subtalar joint to stabilize the joint. I explained that this may or may not lead to a solid
ossification of the subtalar joint but could providers with significant relief.
Vitals:
Date 06/09/2015
Height 62 inches (157.48 cm) Weight 187 pounds (84.82 kg) BMI 34.19
Current Problems:
TRAUMATIC ARTHROPATHY INVOLVING ANKLE AND FOOT (716.17), onset: 05/08/2015, Noted, last
assessed: 06/01/2015
UNSPECIFIED SITE OF ANKLE SPRAIN (845.00), onset: 05/08/2015, Noted
ANKLE INSTABILITY OTHER JOINT DERANGEMENT NOT ELSEWHERE CLASSIFIED INVOLVING
ANKLE AND FOOT (718.87), onset: 05/08/2015, Noted, last assessed: 06/01/2015
PERONEAL TENDON RUPTURE (TRAUMATIC) OTHER ANKLE SPRAIN (845.09), onset: 05/11/2015,
Noted, last assessed: 06/01/2015
PERONEAL TENDINITIS OTHER ENTHESOPATHY OF ANKLE AND TARSUS (726.79), onset:
05/11/2015, Noted, last assessed: 06/01/2015
UNSPECIFIED PRURITIC DISORDER (698.9), onset: 05/11/2015
PAIN IN LIMB (729.5), onset: 05/20/2015, Noted, last assessed: 06/09/2015
POSTSURGICAL ARTHRODESIS STATUS (V45.4), onset: 06/01/2015, Noted, last assessed: 06/09/2015
NONUNION OF FRACTURE (733.82), onset: 06/09/2015
Current Medications:
metformin 500 mg tablet extended release 24 hr, TK 1 T PO EVERY DAY X 30 Days, Start Date:
11/21/2014
omeprazole 20 mg capsule.delayed release(DR/EC), TK 1 C PO QD X 30 Days, Start Date: 11/21/2014
Ambien (Zolpidem) 5 mg tablet Take 1 tablet as directed, Take one about 1 hour pre op. Bring the
medication to the procedure and repeat if needed, Disp. 4 NR, Start Date: 05/11/2015
Printed by Marilee Silvester on 06/16/2015, Page 1 of 2
CPTonr/0 2014 American Madltal Association. AllRights RasarvaO.
Silvester Foot Clinic
409 N. Bryant
Pleasanton, TX 78064
(830)569- 3338
FAX (830)569- 6833
Patient: CASTRO, MARYANN, DOB: 09/23/1965, Age: 49 years, Female
Acct #: 4320
metoprolol succinate 25 mg tablet extended release 24 hr, TK 1 T PO QD X 30 Days, Start Date:
12/01/2014
hydrochlorothiazide 25 mg tablet, TK 1 T PO EVER DAY X 30 Days, Start Date: 11/21/2014
levothyroxine 150 meg tablet, TK 1 T PO EVERY DAY FOR 30 DAYS X 30 Days, Start Date: 11/21/2014
Current Allergies: No Known Drug Allergies
Medical History
Thyroid dysfunction (Yes).
Hypertension (Yes).
Diabetes (Yes).
Arthritis (Yes).
Cancer- breast,
tumors.
Surgical History
Ankle surgery - Right.
hysterectomy.
mastecomy.
Thyroid.
Tumor on ovary.
Throat cyst.
Family History
Diabetes, Type II - Natural Mother.
Cancer - Natural Father - What type of cancer? - Colon; Natural Sister - What type of cancer? - bone.
Social History
Smoking status: Never smoker (266919005).
Smokeless Tobacco Use (No).
Illicit/Recreational Drugs (No),
alcohol use (No).
Alcohol (No).
Printed by Marilee Silvester on 06/16/2015, Page 2 of 2
CPT onlyO 2014 AmericanMsdital Association. AU Rights RoServed.
Edfinancial Services
"PO Box 36014
Knoxville, TN 37930-6014 SERVICES
MARY ANN CASTRO Statement Date: 12/12/14
PO BOX MTS Account Number: C872043321
PLEASANTON TX 7fl0t.M-DM^S
Account Summary: GROUF» F GROUF> G
Loan Type STAFFORD STAFF 3RD
Original Principal Amount $ 1,500.00 $ 2,780.00
Lender Name NTHEA NTHEA
Current Interest Rate 02.330% 06.800%
Current Principal Balance $ 2,076.37 $ 3,375.46
Accrued Interest on next Due Date $ 16.01 $ 12.56
Interest Paid Since Last Statement $ 0.00 $ 0.00
Total PrincipalPaid Through 12/12/14 $ 0.00 $ 0.00
Total Interest Paid Through 12/12/14 $ 0.00 $ 0.00
Total Fees Paid Through 12/12/14 $ 0.00 $ 0.00
Total Amount Paid Through 12/12/14 $ 0.00 $ 0.00
Total PayoffAmount Through 01/02/15 $ 2,099.08 $ 3,401.02
Fees Assessed Since Last Statement:
Late Fees $ 0.00 $ 0.00
Non-Sufficient Fund Fees $ 0.00 $ 0.00
Legal Fees $ 0.00 $ 0.00
Collection Fees $ 0.00 $ 0.00
Servicing Fees $ 0.00 $ 0.00
Current Billing Summary:
Monthly Payment Amount $ 0.00 $ 0.00
'% A
\- .' t
Total Past Due $ 0.00 $ 0.00
Outstanding Fees $ 6.70 $ 13.00
Total Amount Due on statement date $ 0.00 $ 0.00
Penalty for Late Payments:
Charge ifpayment not received by 10/23/15 10/23/15
Late Fee Amount $ 0.94 $ 1.90
J o
ACCOUNT INFORMATION
We're preparing information to show how much student loan interest you paid in2014. It
will be sent to youbythe endof January inyour billing n statement, ifapplicable.
The statement or letter will serve as your official IRSForm 1098-E.You can also
log in at www.edfinancial.com startingJanuary12to view yourtax information.
SEE REVERSE SIDE FOR IMPORTANT ACCOUNT INFORMATION
PLEASE DETACH AND SEND BOTTOM PORTION WITHYOUR PAYMENT
Account Number C872043321
NAME ON CHECK IF DIFFERENT FROM STATEMENT:
Payment Due Date 01/02/15
Total Due $ 0.00
Sign upat www.edfinancial.com for ourconvenient auto-debit payment option and electronic
correspondence.
Check this box for change of address. See reverse side.
Please writeyour account number on your check or
money order. PLEASE DO NOT SEND CASH.
Check this box ifyou completed the special payment instructions on the reverse side.
Ifa check isrelumed unpaid for insufficient funds, itmay berepresented electronically.
Payment Address: MARYANN CASTRO
PO BOX 495
I..II.I...II.I..I.I...I.I.LI ll....l.l..l.l.l.l,.l,l PLEASANTON TX 78064-0495
Ill
Edfinancial Services
Dept. 888055
Knoxville, TN 37995-8055
idssflt^assMaamflssflb a ddddodd i
Edfinancial Services
PO Box 36014
Knoxville, TN 37930-6014 SERVICES
£si!i>i|'lll'»'il''li'l><>i>lillii»il'li>l«>>ll
>0385b, UADS?11]! 001 008167 10Z
Statement Date: 12/12/14
MARY ANN CASTRO Account Number: C872043321
PO BOX MIS
PLEASANTON TX 7aom-DMTS
Account Summary: GROUP A GROUP B GROUP C GROUP D GROUP E
Loan Type STAFFORD STAFFORD STAFFORD STAFFORD STAFFORD
Original Principal Amount $ 2,625.00 $ 4,000.00 $ 3,500.00 $ 4,000.00 $ 875.00
Lender Name NTHEA NTHEA NTHEA NTHEA NTHEA
Current Interest Rate 02.330% 02.330% 02.3307 02.3307 02.3307o
Current Principal Balance $ 3,152.03 $ 5,674.88 $ 4,102.38 $ 5,693.86 $ 1,025.51
Accrued Interest on next Due Date $ 4.02 $ 43.81 $ 5.23 $ 43.94 $ 1.30
Interest Paid Since Last Statement $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00
Total Principal Paid Through 12/12/14 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00
Total Interest Paid Through 12/12/14 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00
Total Fees Paid Through 12/12/14 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00
Total Amount Paid Through 12/12/14 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00
Total Payoff Amount Through 01/02/15 $ 3,166.39 $ 5,736.92 $ 4,121.08 $ 5,756.08 $ ,030.17
Fees Assessed Since Last Statement:
Late Fees $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00
Non-Sufficient Fund Fees $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00
Legal Fees $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00
Collection Fees $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00
Servicing Fees $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00
Current Billinq Summary:
Monthly Payment Amount $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00
Total Past Due $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00
Outstanding Fees $ 10.34 $ 18.23 $ 13.47 $ 18.28 $ 3.36
Total Amount Due on statement date $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00
Penalty for Late Payments:
Charge if payment not received by 10/23/15 10/23/15 10/23/15 10/23/15 10/23/15
Late Fee Amount $ 1.47 $ 2.58 $ 1.91 $ 2.59 $ 0.48
ACCOUNT INFORMATION
We're preparing information to show how much student loan interest you paid in 2014. It
will be sent to you by the end of January in your billing n statement, if applicable
The statement or letter will serve as your official IRS Form 1098-E. fou can also
log in at www.edfinancial.com starting January 12 to view your tax information.
SEE REVERSE SIDE FOR IMPORTANT ACCOUNT INFORMATION
PLEASE DETACH AND SEND BOTTOM PORTION WITH YOUR PAYMENT. Account Number C872043321
NAME ON CHECK IF DIFFERENT FROM STATEMENT:
Payment Due Date 01/02/15
Total Due $ 0.00
Sign up at www.edfinancial.com for our convenient auto-debit payment option and electronic
correspondence.
Check this box for change of address. See reverse side.
Please write your account number on your check or
money order. PLEASE DO NOT SEND CASH.
. _ Check this box if you completed the spedal payment instructions on the reverse side.
If a check is returned unpaid for insufficient funds, it may be represented electronically.
Payment Address: MARYANN CASTRO
PO BOX 495
PLEASANTON TX 78064-0495
I..II.I.mII,I„I,I,„I,I,I„I,II„,.I.I..I I.I..I.Im.mI
Edfinancial Services
Dept. 888055
Knoxville, TN 37995-8055
iDssfib^assMflBmassflb a odddddd i
£?• S>J^> ^f^LINEBARGER GOGGAN BLAIR &SAMPSON, LLP -HpC"~
ATTORNEYS AT LAW
^5 ^
,}-o<2-S u)»Xc
ESTA CORRESPONDENCIA SE TRATA DE SUS IMPUESTOS Y LA POSIB1LIDAD DE UNA DEMANDA ACERCA DE SU PROPIEDAD SI
H-124E
USTED DESEA ASISTENCIA POR UNA PERSONA QUE HABLA ESPANOL, LLAME USTED A(800)876-6144 YUNA PERSONA LE AYUDARA
is>wi,
CASTRO MANUEL & MARYANN
PO BOX 495
PLEASANTON TX 78064-0495
ili"ililll«iliilll','i"l'illlim'hll'»1il I'lli'»i,'lll
RE: Acct. # 17471 CAD#17471 - ABS A01239 J POITEVENT SV-1,9.45 ACRES (see attachedpELINQUENT ACCOUNT
STATEMENT)
NOTICE OF LEGAL ENFORCEMENT
Dear Atascosa County Taxpayer:
Our law firm mailed a letter dated July 16, 2014 advising you to pay your property taxes and they still remain unpaid.
You must contact our office to address this matter and avoid legal action. We have legal representatives ready to assist
you by calling (210) 362-9000.
Failing to contact our office or the Atascosa County Tax Office to pay your taxes can result in a lawsuit being filed
against you seeking the foreclosure of your property. Once a lawsuit is filed, court costs and fees associated with the
lawsuit will be your responsibility. You can avoid legal action and the possibility of foreclosure by contacting our law
office or mailing paymenttoday with the enclosed statement to:
Atascosa County
1001 Oak St
Jourdanton, TX 78026-2849
(830)769-3842
YOU MAY OWE ADDITIONAL TAXES TO ENTITIES NOT SHOWN ON THE ATTACHED STATEMENT. FOR ADDITIONAL
INFORMATION, PLEASE CONTACT THE OFFICE OF THE ATASCOSA COUNTY TAX ASSESSOR-COLLECTOR, LORETTA HOLLEY,
AT (830) 769-3842.
PLEASE DO NOT HESITATE - WE ARE HERE TO HELP YOU. We have been instructed by the Office of the
Atascosa County Tax Assessor-Collector to advise you that ifyou are solicited by a lender offering to loan you money to
pay your taxes through a tax lien transfer loan, be aware that administrative fees and costs are associated with the tax lien
transfer loan. To learn about the options available to you to pay your taxes, contact our law office or the Atascosa County
Tax Office.
Ifyou believe this statement is in error please WRITE to our law office at 711 Navarro Street, Ste 300, San Antonio, TX
78205 and supplythe ACCOUNT NUMBER alongwith your comments.
TEXAS LAW REQUIRES THAT WE NOTIFY YOU THAT IF YOU ARE 65 YEARS OF AGE OR OLDER OR DISABLED, AND YOU
OCCUPY THE PROPERTY DESCRIBED IN THIS DOCUMENT AS YOUR RESIDENCE HOMESTEAD, YOU SHOULD CONTACT THE
APPRAISAL DISTRICT REGARDING ANY ENTITLEMENT YOU MAY HAVE TO A POSTPONEMENT IN THE PAYMENT OF THESE
TAXES.
Sincerely,
Ronald E. Rocha
Attorney at Law
H-163J
ESTA CORRESPONDENCIA SE TRATA DE SUS IMPUESTOS Y LA POSIBILIDAD DE UNA DEMANDA ACERCA DE SU PROPIEDAD. SI
i iSTRndesf.a ASISTENCIA PORUNA PERSONA QUE HABLA ESPANOL, LLAME USTED A (800)876-6144 Y UNA PERSONA LE AYUDARA
TAX RECEIPT 01/05/2015 08:54AM
ATASCOSA COUNTY TAX OFFICE
1001 OAK STREET
JOURDANTON, TX 78026 IlSiillffiNuaSiliiil
1302446
w^mmsf-
Ray|TientsTypej&a»
o^/msP;
RaymentjCode»i« Partial ***!
Miiilitilfi Iiofliboj
PAID BY:
CASTRO MARY ANN
PO BOX 495
PLEASANTON, TX 78064
[Property ID >' -V Geo Legal Acres 7" >~ ,*" 'Owner Name and Address \
• 17471"'•'"•"• "j01?39-00-000-001104 9 4500 'CASTRO MANUEL &MARYANN
PO BOX «195
j^; ./ . f"' : Legal Description PLEASANTON, TX 78064
JABSA0i23£I JPOITEVENT SV 1 9 45ACRES
•A'Sifusf-'y'if. DBA Name
: 'l501 OLIVE ST", '
' Entity r Year Rate taxable Value/' Stmt #. Void _ Original Tax DiscjitJJg|g|^5SISl^Sll^S§M^ffl9lfflMi.'
EVERGREEN WATER
DIST 2013 0.00600 216,300 53838 N 0.90 0.00 0.22 0.16 0.00 1.28
FARM TO MARKET
ROAD 2013 0.07500 238,300 53838 12.50 0.00 3.00 2.33 0.00 17.83
ATASCOSA COUNTY 2013 0.34060 241,300 53838 56.72 0.00 13.62 10.55 0.00 80.89
100.00
Balance Due As Of 01/05/2015: 796.13
Ten'der;S5;!^*j|jii Details Description.^' * "l\ 7, ,rtS1'v Amount
Money" Order '""" 17-133811575 10000
100.00
***Payment code of 'Partial' indicates this transaction is considered a partial payment. Please contact the Tax Office for balance due information.
Operator•':TBatch " __ / *\ "r^ v '"__ •' Tota[Paid
LH " 12840 (01/05/15LH) 10000
Special Condition Exists for this Property
Page: 1 Receipt issued in Accordance with Section 31.075 of the Texas Property Tax Code True Automation, Inc.
BSI Ftnjnctrtl
Sen/ices, Inc.
10/09/2014 Sent Via Certified Mail
1307 HDD 1170 D77D 3513 bfl
Mary Arm Castro
PO Box 495
Pleasanton, TX 78064-0495
Loan Number: 44675
Property Address: 1501 OLIVE STREET
JOURDANTON, TX 78026
NOTICE OF DEFAULT AND INTENT TO ACCELERATE
Dear Mary Ann Castro:
This letter is formal notice by BSI Financial Services, Inc. (herein as "BSI") the Servicer of the
above-referenced loan, on behalf of MLB SUB I, LLC that you are in default under the terms of the documents
creating and securing your Loan described above, including the Note and Deed of Trust/Mortgage/Security
Deed ("Security Instrument"), for failure to pay the amounts due.
The loan is due for 12/01/2011 and subsequent payments, plus late charges, fees and costs. As of today, the
total delinquency and reinstatement amount is $73,967.02, which consists of the following:
Next Payment Due Date 12/01/2011
Total Monthly Payments Due: $66,367.76
(35 @ $1,732.72)
Late Charges $4,204.26
Other Fees: $3,395.00
Unapplied Balance: r$o.oo)
TOTAL YOU MUST PAY TO CURE DEFAULT: $73,967.02
It is possible that after payment of the amounts detailed above there may be other fees still due and
owing, including but not limited to other fees, escrow advances or corporate advances that BSI paid on
your behalf or advanced to your account.
This letter is a formal demand to pay $73,967.02. If the default, together with additional payments that
subsequently become due, is not cured by 11/13/2014, BSI will accelerate the note so that the entire debt is
immediately due and payable, and take steps to terminate your ownership in the property by a foreclosure
proceeding or other action to seize the property.
IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, BSI offers consumer assistance
programs designed to help resolve delinquencies and avoid FORECLOSURE. These services are provided
without cost to our customers. You may be eligible for a loan workout plan or other similar alternatives. If you
would like to learn more about these programs, you may contact the Loss Mitigation Department at (800)
327-7861, Monday-Wednesday 8 am to 8 pm EST, Thursday 8 am to 6 pm EST, Friday 8 am to 5 pm EST,
Saturday 8 am to 12 pm EST. WE ARE VERY INTERESTED IN ASSISTING YOU.
The default above can be cured by payment of the total delinquency and reinstatement amount plus any
W4
TX_NOI
Page 1 of 3
1307 HDD 117D D77D 3S13 bfl
additional payments and fees that become due by 11/13/2014. Note that in addition to the regular monthly
payments, additional charges, costs and fees may become due during the period between today's date and the
date the aforementioned payments are due. You may contact our Collection Department at (800) 327-7861 to
obtain updated payment information.
Please include your loan number and property address with your payment and send to:
BSI FINANCIAL SERVICES
PO BOX 517
TITUSVILLE, PA 16354
or Overnight
BSI FINANCIAL SERVICES
314 S FRANKLIN ST
TITUSVILLE, PA 16354
If you wish to dispute the delinquency, or if you dispute the calculation of amount of the delinquency and
reinstatement amount, you may contact us by calling (800) 327-7861.
You have the right to reinstate the loan after acceleration, and to bring a court action to assert the non-existence
of a default or any other defense to acceleration or foreclosure sale. Failure to respond to this letter may result
in the loss of your property. To the extent your obligation has been discharged or is subject to the automatic
stay in a bankruptcy case, this notice is for informational purposes only and does not constitute a demand for
payment or an attempt to collect a debt as your personal obligation. If you are represented by an attorney,
please provide us with the attorney's name, address and telephone number.
BSI is the mortgage servicer for the mortgagee of the Deed of Trust and the parties have entered into an
agreement granting BSI authority to service the mortgage and represent the mortgagee (the "Servicing
Agreement"). Pursuant to the Servicing Agreement, BSI is granted authority to collect and service debt
associated with the Deed of Trust. Under §51.0025 of the Texas Property Code, BSI, as mortgage servicer, is
authorized to administer any resulting foreclosure of the property covered by the Deed of Trust on behalf of the
Mortgagee. All communication about your mortgage should be made through the Mortgage Servicing
Department of BSI at 314 S Franklin Street, Titusville, PA 16354.
Attention Servicemembers and Dependents: Assert and protect your rights as a member of the armed
forces of the United States. If you are or your spouse is serving on active military duty, including active
military duty as a member of the Texas National Guard or the National Guard of another state or as a
member of a reserve component of the armed forces of the United States, please send written notice of the
active duty military service to the sender of this notice immediately. Servicemembers on active duty, or a
spouse or dependent of such a servicemember, may be entitled to certain protections under the Servicemembers
Civil Relief Act ("SCRA") regarding the servicemember's interest rate and the risk of foreclosure. SCRA and
certain state laws provide important protections for you, including prohibiting foreclosure under most
circumstances. If you are currently in the military service, or have been within the last 12 months, AND joined
after signing the Note and Security Instrument now in default, please notify BSI Financial Services, Inc.
immediately. When contacting BSI Financial Services, Inc. as to your military service, you must provide
positive proof as to your military status. Servicemembers and dependents with questions about the SCRA
TX_NOI
Page 2 of 3 130? HDD 1170 D770 3S13 bfl
should contact their unit's Judge Advocate, or their installation's Legal Assistance Officer. Homeowner
counseling is also available at agencies such as Military OneSource (www.militaryonesource.mil:
1-800-342-9647) and Armed Forces Legal Assistance (http://legalassistance.law.af.mil), and through
HUD-certified housing counselors (http://www.hud.gov/offices/hsg/sfh/hcc/hcs.cfm). You can also contact us
toll-free at (800) 327-7861 if you have questions about your rights under SCRA.
If you are experiencing financial difficulty, you should know that there are several options available to you that
may help you keep your home. You may contact a government approved housing counseling agency which
provides free or low-cost housing counseling. You should consider contacting one of these agencies
immediately. These agencies specialize in helping homeowners who are facing financial difficulty. Housing
counselors can. help you assess your financial condition and work with us to explore the possibility of
modifying your loan, establishing an easier payment plan for you, or even working out a period of loan
forbearance. For your benefit and assistance, there are government approved homeownership counseling
agencies designed to help homeowners avoid losing their homes. To obtain a list of approved counseling
agencies, please call (800) 569-4287 or visit http://www.hud.gov/offices/hsg/sfli/hcc/hcs.cfm.
You may be eligible for assistance from the Homeownership Preservation Foundation or other foreclosure
counseling agency. You may call the following toll-free number to request assistance from the Homeownership
Preservation Foundation: (888) 995-HOPE (4673). If you wish, you may also contact us directly at (800)
327-7861 and ask to discuss possible options.
If your loan was originated as a Texas Home Equity Loan under the Texas Constitution, Article XVI, Section
50(a)(6), your property will be scheduled for foreclosure in accordance with Rules 735 and 736 of the Texas
Rules of Civil Procedure and the Texas Constitution, by obtaining a court order for the foreclosure.
This matter is very important. Please give it your immediate attention.
Sincerely,
BSI Financial Services, Inc.
314 S Franklin Street
Titusville, PA 16354
(800)327-7861
FEDERAL LAW REQUIRES US TO ADVISE YOU THAT BSI FINANCIAL SERVICES, INC. IS A DEBT
COLLECTOR AND THAT THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
MAY BE USED FOR THAT PURPOSE. TO THE EXTENT YOUR OBLIGATION HAS BEEN DISCHARGED OR
IS SUBJECT TO THE AUTOMATIC STAY IN A BANKRUPTCY PROCEEDING, THIS NOTICE IS FOR
INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE A DEMAND FOR PAYMENT OR AN
ATTEMPT TO COLLECT AN INDEBTEDNESS AS YOUR PERSONAL OBLIGATION. IF YOU ARE
REPRESENTED BY AN ATTORNEY, PLEASE PROVIDE US WITH THE ATTORNEY'S NAME, ADDRESS AND
TELEPHONE NUMBER.
TXNOl
Page 3 of 3 13Q7 HDD 1170 D770 3S13 bfi