Mary Ann Castro v. Manuel Castro

1/16/15

Court of Appeals District

Cadena Reeves Justice Center —

300 Dolorosa Suite 3200 ^ f^ .- =

San Antonio Texas 780205-3037 :. = z>'d -^

Honorable Judge LittleJohn (^^
■ •— —o

From: . ~r.--——. — — .

't~* ^" . ■ ■
Maryann Castro Pro-se Appellant ■ '" ^° '

1501 Olive

Jourdanton Texas 7S026

Court Of Appeals Number-04-14-00785

Trial Court Case Number-2011-CI-15957

Motion to Continue to Modify Agreement for Final Divorce Signed By Judge Canales on 10/30/13
contest the Equity of 40,000 using a comparative market analysis using a realtors opinion Appellee
overvalue 1501 Olive Appellant has a Certified Appraisal showing home value225,Q00 the actual value

Honorable Judge

Little John

I Appellant, Maryann Castro pro se, am asking the court, for Justice, In the Agreement for Final Divorce.

Settlement, Manuel Castro due to the false CMA-Comparative Market Analysis, A Realtors Opinion, and
it state not to be used as an Appraisal and it was. Fraud was used I have the Appraisal of Real Property
Certified Appraisal, 225,000. Tax Appraisal is 215,000 see copies

Bankruptcy, Appellee Manuel Castro hid from Appellant MaryAnn Castro, Home mortgage not being
paid. Appellant Maryann Castro, pray for the Court, to relief her of the Agreement For final divorce.

Appellant Maryann Castro is seeking relief from Agreement of the Following facts with evidence listed in
the Final Divorce, 40,000 there is not equity, fraud was set up by Appellee Manuel Castro mistress
Christina Pacheco, to defraud Appellant Maryann Castro, spousal Maintence, with Appellee Manuel
Castro taking part of the fraud.
Appellee Manuel Castro has the martial property in bankruptcy, at the time of Agreement for final
divorce was signed tried to falsely gain, 40,000 in Mortgage Money, hiding the bankruptcy Attorney
Joseph Appelt took part in malpractice processing a divorce without the stay being lifted, and that is a
law that was broken by, Attorney Joseph Appelt, Attorney Dinorah Diaz, Appellee Manuel Castro, and
non-spouse mistress Christina Pacheco took part in defrauding Appellant Maryann Castro of spousal
maintence, overvaluing the property 1501 Olive with a comparative market analysis, instead of a
certified appraisal which is now provided, see copy and tax appraisal see copy.

Appellant Maryann Castro pray for the court to grant her spousal maintence of 800.00 a month
beginning as soon as possible with the date starting 10/30/13 as a payment Appellant Maryann Castro
will accept the Johnson Control retirement Manuel Castro withheld, in the amount of 11,000 spousal
maintence to be continued for 10 years, Appellant Maryann Castro is disabled and needs housing
financial assistance to be provided, by Appellee Manuel Castro.

Appellant Maryann Castro pray for the court to grant her 1501 Olive her homestead, not to be sold, due
to Appellee Manuel Castro misleading the Court, Appellant Maryann Castro is disabled, 1501 Olive is her
home life she never abandoned, Appellant Maryann Castro, paid Attorney Matthew Obremier to stop
foreclosure, which would of happened 1/06/15 Appellant Maryann Castro, paid 3500 of her social
security disability money, to stop foreclosure.

Appellant Maryann Castro is asking the Court for Appellee Manuel Castro to reimburse her all attorney
fees spent 20,000 for it is the Appellee Manuel Castro who committed adultery, fraud, and abandoned
his role as provider, spouse, of Appellant Maryann Castro who is disabled and became disabled within
the marriage and did not support Appellant through the Separation which began on or about 7/4/2011.

Maryann Castro Appellant pray for the Court to honor her relief and award her Spousal Maintence,
Attorney Fee, non-sale of homestead 1501 olive Jourdanton Texas.

Respectfully^

Ms. Maryann Castro Pro Se Appellant <-> - j ) / . . i ,-

1501 Olive

Jourdanton Texas 78026

830-496-0133

Pacattitude2014@gmail.com
 1/16/15

Enclosed

Appraisal of real property certified 225.000 a certified appraisal is the true value of 1501 Olive not a
Comparative Market Analysis realtors opinion was used Appellee used his mistress realtor friend Archie
Marmejo set it up to overvalue at 351,000 it was filed and used to defraud Appellant Maryann Castro of
Spousal Maintence.

Taxes I am paying copy appellee not paid

Social security 2013 income

I could not afford to do the things in the agreement for Divorce house was not being paid, in
foreclosure, bankruptcy appellee Manuel Castro did not tell the court hid from appellant Maryann
Castro Attorney Joseph Appelt and Attorney Dinorah Diaz hid this fact from Judge Canales, the stay was
not lifted on 10/30/13.

Dec 15, 2014 balance 79019.30

Note balance owed 275251.54 as of Nov 2014

Manuel Castro evidence of bankruptcy

Dated 7/31/14 Appellant Maryann Castro paid for bankruptcy stay to be lifted Appellee Manuel Castro
and Attorney Joseph Appelt proceeded in trying to collect financially illegally Appellee was in bankruptcy
not paying the mortgage.

Comparative Market Analysis, prepared for Appellant Maryann Castro 184,000

Comparative market analysis prepared for Appellee Manuel Castro mistress had prepared by realtor
friend showed 351,000 fraud.

Mistress involvement in Marriage Christina Pacheco

BSI 73,967.02 statement proof Appellee owes mortgage no equity in 1501 Olive

Tax Appraisal 215,000 on or about Appraisal Property certified at 225,000 not 351,000

Bankruptcy showing Appellee filed Appellant Maryann Castro never notified

Harassment of Mistress Christina Pacheco at 1501 Olive

Income of appellant Maryann Castro disabled

Proof of affair committed Adultery notified by Christina Pacheco husband she is known as Tina Pacheco
Appellant Maryann Castro prays for relief of Final Divorce Agreement signed on 10/30/13 no equity
awarded to Appellee Manuel Castro due to fraud, Adultery, discrimination of a disabled person Appellee
Manuel Castro Brought this to Appellant Maryann Castro when he abandoned his home and marriage to
appellant Maryann Castro and Committed Adultery with Christina Pacheco both who committed fraud in
the Agreement for Final Divorce signed on 10/30/13.
 M18*1 OF RBU. PROPERTY

, LOCATED AT:
8165 FM 2146

Jowtfamon,™ 78028

FOR:

SanAntorio. Tma 78218

AS OF:
Oecembar is. 2QQ5

BV:
y

13720 Attotts Wal3 Drive
Hcloto, Taras 7BQ23

(210) 695-ttCO

LINEBARGER GOGGAN BLAIR & SAMPSON, LLP
ATTORNEYS AT LAW
M-- «*- 711 Navairo Street, Ste 300
/ \ San Antonio. TX 78205 \
Av v> ^
■-V * -

L ° PHONE: (210) 225-4422 FAX: (210) 231-0963 \
(800)876-6144 *•

IS)I July 22,2014 \
\^>

T3-P0-SJSS

fjgP4
1W7976850
A
PLEASANTON TX 78064-«95

ACCOUNT REFERRED FOR LEGAL ENFORCEMENT
Atascosa Count.- Taxpayer:

aw firm has been retained to institute forced collection procedures to collect the Atascosa County delinquent taxes
on the above referenced account. This letter and the detailed tax statement enclosed are JotSSSK SZ
iinquent and must be paid immediately to avoid legaUnforcement.

-list make payment within ten. (10) days fronuhe date of this letted In order to avoid legal enforcement you should
payment immediately by returning the enclosed statement along wfofyour check payablVto:

/ Atascosa County >
1001 Oak St I
Jbnrdanton, TX 78026-284^-
(830)769-3842 y

ADDITIONAL TAXES TO ENTmES^NOI_SHOWN ON THE ATTACHED STATEMENT FOR
LEASE C0NTACT ™0FFICE 0F ^ATASC0SA C0UNTY TAx SSIS: 5k
lieve this statement is m error, orftat you are entitled to an exemption, or ifyou do not own please
ens law office at 711 Navarro Street,, Ste 300, San Antonio,
300, San TX 78205
Antonio, TX 78205 and
and supply
supply the
the ACCOmf
= your comments. If
= your comments If you
you need
need to
to set
set up a paymentt plan,
l contact our office at (^00)^44
a. Ifyou have an active payment plan, a lawsuit will not be filed. ■

Sincerely,

ArfJL

Ronald RRocha \
AttorneyatUw

CORKESPONDENCIA SE TRATA DE SUS IMPUESTa«5 Y I.A PfKIRH man nc iivt*
 TAX RECEIPT 01/05/2015 08:54AM

ATASCOSA COUNTY TAX OFFICE
1001 OAK STREET
Receipt Number
JOURDANTON, TX 78026
1302446
Dale Posted 01/05/2015
Payment Type P
Payment Code Partial —
Total Paid $100.00

PAID BY:

CASTRO MARY ANN
PO BOX 495
PLEASANTON. TX 78064

Property ID Geo Legal Acres Owner Name and Address
17471 01239-00-000-001104 9.4500 CASTRO MANUEL & MARYANN '
PO BOX 405
Legal Description
PLEASANTON, TX 78064
ABS A01239 J POITEVENT SV-1.9.45 ACRES
Situs DBA Name
1501 OLIVE ST ,

Entity Year Rate Taxable Value Stmt# Void Original Tax Dlscnts P&l Att Fees Overage Amount Pd
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 0.07600 238.300 53838 N 12.50 0.00 3.00 2.33 0.00 17.83
ATASCOSA COUNTY 2013 0.34060 241.300 53838 N 56.72 0.00 13.62 10.55 0.00 80.89
100.00

Balance Due As Of 01/05/2015: 796.13

Tender Details Description Amount
Money Order 17-133811575 100.00
100.00

A

' Payment code of •Partial1 indicates this transaction is considered a partial payment Ploase contact the Tax Office for balance due Information.

Operator Batch Total Paid
LH 12840 (01/05/15LH) 100.00

Special Condition Exists for this Property
Page 1 Receipt issued in Accordance with Section 31.075 of the Texas Property Tax Code
Social Security Administration

Date: June 5, 2013
Claim Number: XXX-XX-5895A

™000020
PO BOX 495
PLEASANTON TX 78064-0495

you may send them this letter anyone else to have this information,

Information About Current Social Security Benefits

deISs iseC$Tm30°12' the fUl1 m°nthly S0dal Securi* benefit before any
We deduct $0.00 for medical insurance premiums each month.

Your Social Security benefits are paid on or about the third of each month.
Type of Social Security Benefit Information
You are entitled to monthly disability benefits.
If You Have Any Questions

3
i
>

SOCIAL SECURITY I
3438 E SOUTHCROSS
SAN ANTONIO, TX 78223

See Next Page
 CAUSE NO.

IN THE DISTRICT COURT

ICIAL DISTRICT

QU*Al(?flStyD BEXAR COUNTY, TEXAS

Ar.RFF.MF.NT FOR Pt'/NoJ
On the 30 day of ,20 , came on to be heard the above styled

and numbered cause of action. **
Petitioner and Respondent appeared in person and announced ready. After conference, the
parties reached an agreement on the terms and conditions set forth below.
By the signatures below the parties acknowledge that this agreement expresses the entire
understanding and accord of the parties in consent that the Court may, without further notice, enter

binding orders in accordance with this agreement.

•2. o-f
W.
OS an
nbuiis> ^6,000

jj

Pebfe > S^ Hrhe. debfe in4Viei/

Page 1 of 2 Parties/Attorneys Initials
 CAUSE NO. i

Temporary/Permanent Injunction:

&.yip &eW tea II cku-Wfltte rtpf-essav^ jo

See

SIGNED and ENTERED on this day of 20

JUDGE PRESIDING

APPROVED AS TO FORM:

=2>

Attorney for Respondent
OM "vXa.2.

APPROVED AS TO FORM AND SUBSTANCE:
(Please provide complete mailing address below.)

Responded (signature) \i\ixty N\Y\

If Respondent or Petitibnerls unrepresented, always include a mailina address. /

Page 2 of2
 —• V «-/ V -f I

^ A H
^
i

1*501

Kwu fw\ Casho shft-H iis&- due di'liywA i^
fo
^^F yh j* • ^^^* ft Jl ^§ t 4

mm.

fVn Is Uvxie
MWu)el fl^ivnVs
homf
h pon 0/

4^e/homeshJl
so ^4q,oqo stull pcu^lb

\
 V-dbaAJ ay\L r\^ds h
(Y

o,

\

\
\
\

\
\

X
X
\
X
X
V
l
 151B-ZS4-B3
LIFT TO OPEN CU1292884- 11A41293272

Revenue
703 below, to see ifany
Social Security benefits are
2012"-
taxable. Do not return this form
ofSocial Security we paid you in column headed "Description of
to us or the IRS. Do not attach it
2012. This amount mav not agree Amount in Rnx 4"

FORM SSA-1099 - SOCIAL SECURITY BENEFIT STATEMENT

OHIO * PART 0F Y0UR S0CIAL SECURITY BENEFITS SHOWN IN BOX 5 MAY BE TAXABLE INCOME.
^U !£■ • SEE THE REVERSE FOR MORE INFORMATION.
Box I.Name Box 2. Beneficiary's Sodal Security Number

MARYANN CASTRO

Box 3. Benefits Paid in 2012 Box 4. Benefits Repaid to SSA in 2012 Box 5. Net Benefits for 2012 (Box 3 minus Box 4)

$11,892.00 NONE §11,892.00

DESCRIPTION OF AMOUNT IN BOX 3 DESCRIPTION OF AMOUNT IN BOX 4

Paid by check or direct deposit. $ 11,892.00 NONE
Benefits for 2012 $11,892.00

Box 6. Voluntary Federal Income Tax Withheld

NONE

Box 7. Address

MARYANN CASTRO
PO BOX 495
PLEASANTON TX 78064-0495

Box 8. Claim Number (Use this number if you need to contact SSA.)

458-43-5895A

Pnrm RCA.inoo.eM M.9nii
dD •L°N ST XNaCEJDam 1VO37

/i fff«en

IS
 F>S! rin» BROKBi PRICE OPINION OR COMPARATIVEMARKETANALYSISAND SHOULD NOT BE 00NSIDBtB> AN APPRAISAL In
maWng any decision Hat relies upon my worig. you sheuW know that I hsva not foBov/ed the guidelines for development of an appraisal
or analysis contained in the Uniform Standards of Professional Appraisal Practice of the Appraisal Foundation.

Prepared By: Archie Narmolejo AH Season Realty

innnnnii
 14:3«

ftETn-EMEWT AND WAIVER OP PROTEST

274 S4TH STREET Account* 01239-004)00-001104
Case #:2014-9
POTEET.TX 78085

Prop ID: 17471
Legal Desc: ABS A01239 J POITEVENT SV-
1,9.45 ACRES

54028
CASTRO MANUEL & MARYANN
PO BOX 495
PLEA8ANTON, TX 78064
Date:05/07/14 - ' ' O-

SETTLEMENT AND WAIVER OF PROTEST

I acknowledge
iSyrtMn-r r^^tand waive my r^htto any further proceeding In this
above has been settled. I
matter.

Describe actions to be taken: /°

DP.HS
EXEMPTIONS:
$0
LAND AG VALUE:
$54,810
LAND HOMESTEAD VALUE- $54,810
LAND MARKET VALUE
$159,770
IMPROVEMENT VALUE:
$214,680
TOTAL MARKET VALUE:
$214,580
. NEW ASSESSED VALUE:

Property owner /

sign yt-/"Y
hare * A1 I
urailon

here «*►

Order

I with a quorum present
Qnttte davof
ordered that the i
2/13/2012

TO: EDWARD PIKER ATTORNEY FOR MARY ANN CASTRO

FROM: RUDY PACHECO

EVIDENCE OF AFFAIR MANUEL CASTRO HAS BEEN HAVING WITH MY WIFE

ON OR ABOUT 7/3/11 THAT'S WHEN THE AFFAIR BEGAN

I RUDY PACHECO AM A WITNESS TO THE FOLLOWING:

MANUEL CASTRO, HAS BEEN HAVING AN AFFAIR WITH MY WIFE TINA
PACHECO THEY LIVED TOGETHER IN ELMENDORJ ON HICKORY
SHAWDOW WITH MANUEL CASTRO SISTER, LEILA SILVA AND HER

FROM^LY^/utoAUG 18/11 SHE LEFT ME SAID SHE WANTED SOME TIME
ALONE SHE WAS LVING WITH MANUEL, And I QUESTIONED HER TALK TO
HER DAILY WE WOULD GO EAT DAILY. SOMETHING DID NOT SEEM RIGHT,
BECAUSE MY WIFE OF 30 YEARS DID NOT WANT TO BE HOME AT OUR

^Tc^O^IZl^l EVEN THOUGH HE «™ AND 1
WFRE MARRIED I WOULD SEE HIM STALKING OUR HOME, I ASKED MY
wfFE O^ND OV^ER WHO WAS MANUEL CASTRO, SHE CLAIMED SHE DID
NOT KNOW HE KEPT CALLING HER BOTHERING HER MANUEL CASTRO HAS
A WIFE WHOM 1 KNEW AND WAS NOT AWARE HER HUSBAND WAS
CM LING MY WIFE AND STALKING HER.
FROM THE AFFAIR THAT BEGAN IN JULY 3. 201II NOTICED MY WIFE
TEXTING MARYANN CASTRO AND I QUESTIONED HER SHE WOULD CALL
MS MARY ANN CASTRO CRAZY AND THAT MS CASTRO WAS THE ONE THAT
WAS TEXtInG HER I MET MS CASTRO AND COME TO FIND OUT MY WIFE
TINA PACHECO WAS CALLING HER HUSBAND AND HARRASSING MS
CASTRO I DID NOT KNOW MY WIFE HAD BEEN CALLING MANUEL CASTRO
SHE KEPT SAYING SHE DID NOT KNOW AND DID NOT KNOW WHAT HE
WANTED SHE LIED. SHE RETURNED HOME AFTER BEING AWAY ALMOST
TWO MONTHS,SHE WAS LIVING IN ELMENDORF WITH MANUEL
CASTRO.THE AFFAIR DID NOT STOP EVEN THOUGH SHE RETURNED HOME

MY V?IFEBTINA PACHECO WOULD RUN OFF AT WEEKENDS, SHE WOULD BE
TEXTING MANUEL CASTRO AND MANUEL CASTRO WOULD BE CALLING
HER EVERYTIME MY WIFE RAN OFF WITH MANUEL CASTRO, WHEN HE
WOULD CALL, SHE RETURNED WITH HICKEYS, WAS OUT LATE SOMETIME
NEVER RETURNED.HOME . SHE MADE ALL SORTS OF EXCUSES TO GET OUT
OF THE HOUSE.
MARYANN CASTRO HAS BEEN THE ONE WHO HAS BEEN HARRASSED BY
MY WIFE TINA PACHECO BECAUSE MY WIFE HAD BEEN HAVING A SEXUAL
AFFAIR WITH MANUEL CASTRO.
MY WIFE TINA PACHECO HANDLED MY MONEY I WOULD CASH MY CHECK
AND HAND HER MY MONEY SHE NEVER PUT ME ON OUR ACCOUNT I
WOULD SEE THE BANK STAEMENT STATEMENT COME TO FIND OUT SHE
WAS USING MY MONEY TO PAY FOR HOTEL ROOMS, CLOTHES, BOOTS, GO
OUT TO EAT, PAID HIS CELL PHONE BILL, GIVE HIM MONEY, WITH MY

^00-8585 IS MANUEL CASTRO CELL PHONE NUMBER I CALLED HE
CALLED ME BACK TOLD ME HAS MY WIFE SAID SHE LOVED ME THAT HE
DID WANT PROBLEMS WITH ME OR MY SONS, ABOUT 1AM ON OR ABOUT
9/14/1 l'HE WAS DRUNK, HE TOLD ME HE AND MY WIFE WERE HAVING AN
AFFAIRAND SHE WAS PAYING WITH MY MONEY FOR HER AFFAIR WITH

i^TED QUESTIONING MY WIFE ABOUT MONEY BECAUSE ON FRIDAY 1
WOULD GET HOME EARLY SHE WOULD NOT BE HOME SHE WOULD TAKE
OFF FROM OUR HOME NEVER CALLED ME I WOULD KEEP CALLING HER
UNTIL SHE RETURNED I KNEW SHE WAS RUNNING AROUND WITH MANUEL
CASTRO SHE KEPT DENYING SAYING SHE WAS AT HER MOMS, SISTER, A

MANUEL CASTRO^SAT FAULT FOR BREAKING UP MY MARRIAGE HE KEPT
CALLING MY WIFE TINA PACHECO,I SAW HIS NUMBER ON CALLER ID AND
1 SAW HIS SISTER LEILA SIVA ON CALLER ID, MY WIFE TINA PACHECO
WOULD GET MAD WHEN I QUESTIONED HER ABOUT HER WHERE ABOUTS.
ON 10/13P011 MY WIFE TINA PACHECO LET ME AGAIN, SHE LEFT OUR
GOODWIN HOME AND RAN OFF WITH MANUEL CASTRO, COME TO FIND
OUT MANUEL AND MARYANN CASTRO ARE DIVORCING, BECAUSE OF MY
WIFE HAVING AN AFFAIR WITH MANUEL CASTRO,THESE TWO PERSONS
ARE AT FAULT FOR OUR MARRIAGES ENDING,
I KNOW MS MARYANN CASTRO HAD TRIED TO HOLD ON TO HER
MARRIAGE AS I DID THE SAME, BUT MY WIFE KEPT CALLING HER
HUSBAND MANUEL CASTRO AND SHE DID NOT RESPECT MS MARYANN
CASTRO <=HELIVED WITH MANUEL CASTRO/THREATEN MS MARYANN
CASTRO,VERBALLY,TEXT,EVEN STALKED HER BECAUSE SHE WAS HAVING
AN AFFAIR WITH MANUEL CASTRO.
TILL THIS DAY MY WIFE TINA PACHECO AND MANUEL CASTRO ARE
LIVING AT MY HOME THAT 1 BOUGHT ON GOODWIN STREET,ON GOODWIN
IN PLEASANTON TEXAS,SHE HAD MS MARYANN CASTRO
ARRESTED CLAIMING SHE HAD HARRASSED HER 1/25/26/2012,MS CASTRO
WAS AT WORK,SHE HAD BEEN THREATENED BY BY WIFE, MANY TIMES
SHE WAS GOING TO HAVE HER ARRESTED.BECAUSE SHE KNOWS PEOPLE
IN LAW ENFORCEMENT.JUDGE GUERRA.OFFICER VELASQUEZ,MS
MARYANN CASTRO IS THE WIFE OF MANUEL CASTRO,WHOM MY WIFE
LEFT ME FOR BEGINNING 7/3/11 AS OF NOW, I HAVE SEEN HER TEXT MS
MARYANN CASTRO AS I SAID SHE DID HARRASS MS MARYANN CASTRO
MANY TIMES, BECAUSE MY WIFE TINA PACHECO IS BITTER THAT HER
MARRIED LOVER MANUEL CASTRO HAS A WIFE OF 28 YEARS WHOM SHE
KNEW SHE IS THE WIFE OF HER LOVER MARRIED MANUEL CASTRO WHOM
SHE HAS BEEN HAVING A SEXUAL AFFAIR WITH SINCE JULY3.2011 AS OF
NOW THEY HAVE CONTINUED THEIR SEXUAL AFFAIR IN MY HOME IN
PLEASANTON TEXAS ON GOODWIN STREET .February 13, 2012

RESPECTFULLY

MR RUDY

IF I CAN BE OF ANY ASSISTANCE
PLEASE CALL ME AT
MY ATTORNEY IS DINORAH DIAZ
2325 VANCE JACKSON
SAN ANTONIO TEXAS
78213

Given under my hand and seal this 18th day of February, 2012

DEHOYOS
;x-'otafv p"blic. State oi Texas
V:/-.r>v-"/ M
My C Commission Expires
p
Notary Public
'■'■•«< «»*V Janunrv
January 15 om ■»
15. 2013
 2A11CUSSS7 -P0R035

NO.20U-CI-I3957

IN THE MATTER OF § IN THE DISTRI
THE MARRIAGE OF §
§
MANUEL G.CASTRO § 45TH JUDICIAL
AND §
MARYANNCASTRO § BEXARCOUNTY,

SECOND AMENDED COUNTERPET1TION FOR DIV

1. Discovery Level

Discovery in this case is intended to be conducted under level 1 of rule 190 of the Texas

Rules of Civil Procedure. No children are involved in this divorce case, and the value of die

marital estate is more than zero but not more than $50,000.

2. Parties

This suit is brought by Mary Ann Castro, Counterpetitioner. The last three numbers of

Mary Arm Castro's driver's license number are 782. The last three numbers of Mary Ann

Castro's Social Security number are 895.

Manuel G. Castro is Counterrespondent Tina Pacheco is a third party Non Spouse

Defendant.

3. Domicile

Counterrespondent has been a domiciliary of Texas for me preceding six-month period

and a resident ofthis 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 Counterrespondenfs attorney of record, Joseph P. Appelt, 5825 Callaghan

Rd, Ste. 104, San Antonio, Texas 78228.

DOCUMENT
SCANNED AS
FILED
 3II1CXJ99S7 -P0BO35

WO. 2D11-CI-1S957

IN THE MATTER OF § INTHEDISTRI
THE MARRIAGE OF §

MANUEL G.CASTRO 45TH JUDICIAL
AND §
MARY ANN CASTRO § BEXARCOUNTY,1

SECOND AMENDED COUWTERPETITION FOR DIV<

1. Discovery Level

Discovery in this case is intended to be conducted under level 1 of rule 190 of the Texas

Rules of Civil Procedure. No children are involved in this divorce case, and the value of the

marital estate is more than zero but not more than $50,000.

1 Parties

This suit is brought by Mary Ann Castro, Counterpetitioner. The last three numbers of

Mary Ann Castro's driver's license number are 782. The last three numbers of Mary Ann

Castro's Social Security number are 895.

Manuel G. Castro is Countenespondent Tina Pacheco is a third party Non Spouse

Defendant.

3. Domicile

Coimterrespondent has been a domiciliary of Texas for the preceding six-month period

and a resident ofthis 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, 5825 CaUaghan

Rd, Ste. 104, San Antonio, Texas 78228.
DOCUMENT
SCANNED AS
FILED
0''

Service of this document may be had in accordance with Rule 21a, Texas Rules of Civil

Procedure, by serving Tina Pacheco at 624 West Goodwin, Pleasanton Texas 78064.

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 ofMarriage andSeparation

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. Groundsfor Divorce

The marriage has become insupportable because of discord or conflict of personalities

between Counterpetitioner and Counter-respondent that destroys the legitimate ends of the

marriage relationship and prevents any reasonable expectation ofreconciliation.

Counterrespondent is guilty of cruel treatment toward Counterpetitioner of a nature that

renders further Irving together insupportable including commiting assault on Counterpetitioner.

Counterrespondent has committed adultery.

Counterrespondent has left Counterpetitioner with the intention of abandonment and has

remained away for at least one year.

8. Child ofthe Marriage

There is no child born or adopted of this marriage, and none is expected.

9. Division ofCommunity Property

Counterpetitioner believes Counterpetitioner and Countenespondent will enter into an

agreement for the division of their estate. If such an agreement is made, Counlerpetitumer

requests the Court to approve the agreement and divide their estate in a manner consistent with
 ,■ i

Service of this document may be had in accoidance with Rule 21a, Texas Rules of Civil

5. Protective Order Statement

No protective order under title 4 ofthe 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 ofMarriage 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. Groundsfor Divorce

The marriage has become insupportable because of discoid or conflict of personalities
between Countetpetitioner and a>unterrespondent that destroys the legitimate ends of the
marriage relationship and prevents any reasonable expectation ofreconciaatioiL

Counterrespondent is guilty of cmel treatment toward Counterpetitioner of a nature that
renders further living together insupportable including commiting assault on Counterpetitioner.
Counterrespondent has committed adultery.

Counterrespondent has left Counterpetitioner with the intention of abandonment and has
remained away for at least one year.

8. Child ofthe Marriage

There is no child bom or adopted of this maniage, and none is expected.

9. Division ofCommunity Property

Counterpetitioner believes Counterpetitioner and Counterrespondent will enter into an
agreement for the division of their estate. If such an agreement is made, Coimterpetraoner
requests the Court to approve the agreement and divide their estate in a manner consistent with
 ATASCOSA COUNTY SHERIFF'S OFFICE

1108 Campbell Ave.
Jourdanton, Texas 78026

Qffice-(830) 769-3434

Fax-(830) 769-2721

David Soward atascosa.county.sheriff@acso-tx.org

Sheriff

Complainant/Property Owners:

Regarding
g Case # Dated "%1-lOn The Atascosa County Sheriffs Department

has been requested by the above named complainant to act with the authority in the following:

Texas Penal Code Section 30.05-Criminal Trespass
(a) A person commits an offense if the person enters or remains on or in property of another, including residential land, agricultural
land, a recreational vehicle park, a building, or an aircraft or other vehicle, without the effective consent and the person:
(1) Had notice that the entry was forbidden; or
(2) Received notice to depart but failed to do so.

his written order is hereby served to the below individual, imparting immediate, effective notice that
nuance onto the property to wit; 1561 flUuS ST JwdWK^ TV 7%^^ in Atascosa County is forbidden.
,y order of the complainant/property owner's, entrance to the property described above is forbidden until complainant has contacted the
.tascosa County Sheriff's Office in person and in writing, asking that the Criminal Trespass Notice be lifted. Any entrance onto the above listed
roperty will constitute a violation of the law. A violation of the Texas Criminal Trespass statue may be subject for criminal prosecution under
exas Law, punishablfby confinement in jail for a term not to exceed one (1) year and/or a fine not to exceed $4,000.00.

j
1 (f APPn acknowledge that I have received, read, and understand the above written Criminal
respass Warning, and that I have received a copy of the same.

m4-;/is. ho\)pQd
J

Date
ame of Person Warned Date of Birth Signature
S

I
fputy s Signature Date