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In the Fourth Court Of Appeals
Fourth Court Of Appeals District
2015MAY 18 PH |:U2
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
MOTION TO JUST AND RIGHT DIVISON OF THE COMMUNITY ESTATE DUE TO FRAUD OVERVALUED
COMMUNITY WITH REALTORS OPINION AND BANKRUPTCY LIFT STAY NOT FILED AND MORTGAGE
PAYMENTS WERE NOT BEING MADE BY APPELLEE MANUEL CASTRO AND HIDING OF MARTIAL ASESTS 99
SUBARU AND KEOGH PLAN PENSION
TO THE HONARABLE JUSTICES OF THE FOURTH COURT OF APPEAL
Here come Appellant Maryann Castro who is pra-se in Appeals Court and prays for Justice the
wronged spouse should be fully Compensated for Cause of Action for fraud Committed against the
Community VICKERY V VICKERY 999 SW 2D 342,343(TEX 1999)
A Redivision of Community Estate and for actual punitive damages against Appellee Manuel Castro
and 3rd party non spouse mistress Christina Pacheco and Attorney Joseph Appelt were involved in
fraud On Oct 30, 2013 husband Appellee Manuel Castro is liable for fraud and breach of fiduciary duty
caused to harm Appellant Maryann Castro spouse of 29 years the Following occurred to harm
Appellant Maryann Castro.
A} Loss of martial property
Appellee Manuel Castro disposed martial asset 95 fleetwood mobile home financed by
Greentree and Mistress Christina Pacheco was involved in disposing a martial asset she had no
interest or right to even get involved sent text to Appellant Maryann Castro see text
B) Loss of home equity
Appellee Manuel Castro was not paying the mortgage as ordered by the Court when Appellee
Manuel Castro and Appellant Maryann Filed for divorce on or about Oct 2011 and Appellee
Manuel Castro mistress Christina Pacheco was involved sent text to Appellant Maryann Castro
sorry Court or not no house payment Appellee Manuel Castro was paying for his adulterous
Affair using Community funds he stopped direct deposit and moved in with the mistress
nonspause Christina Pacheco who herself was married and knew Appellee Manuel Castro was
married to Appellant Maryann Castro Attorney Dinorah Diaz was The non-spouse mistress
Christina Pacheco husband Attorney Rudy Pacheco who has record of the Adulterous Affair
Appellee Manuel Castro was Having with Non Spouse Mistress Christina Pacheco who is part
of this lawsuit brought in Court by Appellant Maryann Castro Appellee Manuel Castro was
paying for his adulterous affair instead of paying the home mortgage Appellee Manuel Castro
put in bankruptcy and still was not paying the home mortgage as he agreed to when Appellee
Manuel Castro filed for bankruptcy on or about August 2O12.Appellee Manuel Castro was
causing harm to Appellant Maryann Castro continued his adulterous affair with Christina
Pacheco and not paying the home mortgage as ordered by the Court Oct 2011.
C) Punitive damages
Spousal Support 1500 Monthly Appellee Manuel Castro is a welder gets paid weekly
Appellant Maryann Castro did not give up her right to Spousal Support it should have been
enforced in the Agreement for final Divorce Oct 30,2013 Counsel Joseph Appelt wrote on the
Agreement no spousal Support after signature were written another fraud attempt made to
hurt Appellant Maryann Castro the disabled spouse of Appellee ManueL Castro for 29 years.
D) Appellee Manuel Castro and Counsel Joseph Appelt and 3rd party non spouse mistress
Christina Pacheco caused harm to hurt Appellant Maryann Castro by husbands dishonesty
Appellee Manuel Castro the purpose of overvaluing the Community and hiding martial assets
was to deceive Appellant Maryann Castro to cause harm and mental anguish Appellant
Maryann Castro has suffered extreme depression, loss of income, loss of job due to the
dishonesty of Appellee Manuel Castro who has had aver a year to be honest with the Appeals
Court about the bankruptcy, overvalued the Community hiding martial assets, disposed
martial asset ,and not paying the home mortgage Appeals Court has copy's of evidence of
wrongdoing instead Appellee Manuel Castro and Counsel Joseph Appelt and 3rd party non
spouse Christina Pacheco rather let this case drag on for over a year and Conspired to Commit
fraud on the Community and hiding martial assets costing Appellant Maryann Castro
thousands of Dollars and extreme mental anguish depression almost losing the Community to
foreclosure on Jan 6,2015 for non-payment of taxes mortgage Attorney Matthew Obremeier
was retained to protect the Community for Appellant Maryann Castro and is still active in
Atascosa Courthouse due to nonpayment of mortgage and this was caused by Appellee
Manuel Castro. Case of Schlueter v schlueter 975 S.W. 2D 584(TEX 1998){JHECHT
DISSENT1NG}(2) INTRODUCES NEW TEXAS FAMILY CODE SECTION 7.009 CODIDYING
SCHLUETER(3)
Appellant "Maryann Castro prays for Justice and relief she is entitled Appellant Maryann Castro
is pro se
1501 Olive
Jourdanton Texas 78026
8304960133
Pacattitude2014@gm
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