ACCEPTED
06-15-00007-CV
SIXTH COURT OF APPEALS
TEXARKANA, TEXAS
8/11/2015 4:01:54 PM
DEBBIE AUTREY
CLERK
No. 06-15-00007-CV
In the Court of Appeals for the FILED IN
6th COURT OF APPEALS
Sixth Judicial District of Texas TEXARKANA, TEXAS
Texarkana, Texas 8/11/2015 4:01:54 PM
DEBBIE AUTREY
Clerk
HYDROGEO, LLC AND FIRST BANK & TRUST EAST TEXAS
Appellants
AND
DEBERRY 3 OPERATING COMPANY, LLC,
Appellants
v.
QUITMAN INDEPENDENT SCHOOL DISTRICT, WOOD COUNTY, UPPER SABINE
WASTE DISPOSAL DISTRICT, AND WOOD COUNTY CENTRAL HOSPITAL DISTRICT,
Appellees
_______________________________________
On Appeal from the 402nd Judicial District Court
Wood County, Texas
HYDROGEO, LLC and FIRST BANK & TRUST EAST TEXAS’ REPLY TO
QUITMAN INDEPENDENT SCHOOL DISTRICT, WOOD COUNTY, UPPER
SABINE WASTE DISPOSAL DISTRICT, AND WOOD COUNTY CENTRAL
HOSPITAL DISTRICTS’ BRIEF
J. DON WESTBROOK
Texas Bar No. 21215500
COGHLAN CROWSON, LLP
1127 Judson Road, Suite 211
Longview, Texas 75601
(903) 758-5543
(903) 753-6989 (fax)
dwestbrook@ccfww.com
ORAL ARGUMENT REQUESTED Attorneys for Hydrogeo, LLC and
First Bank & Trust East Texas
TABLE OF CONTENTS
Page
INDEX OF AUTHORITIES.......................................................................... iii
SUMMARY OF REPLY ................................................................................ 1
ARGUMENT AND AUTHORITIES ............................................................. 3
A. Issue No. 1 ....................................................................................... 3
B. Issue No. 2 ....................................................................................... 9
GOOD CAUSE DOES NOT EXIST .............................................................. 7
COURT’S ERROR CAUSED IMPROPER JUDGMENT ............................ 8
TAXES WERE ASSESSED ON BOTH REAL AND PERSONAL
PROPERTY ................................................................................................... 9
CONCLUSION ............................................................................................. 12
PRAYER ....................................................................................................... 12
CERTIFICATE OF COMPLIANCE ............................................................ 13
CERTIFICATE OF SERVICE ..................................................................... 14
INDEX OF APPENDICES ........................................................................... 15
ii
INDEX OF AUTHORITIES
Cases Page
Williams vs. County of Dallas 194 S.W.3d 29
(Tex. App.—Dallas 2006 pet den’d) ................................................ 4, 5
Lopez vs. La Madeleine of Texas, Inc., 200 S.W.3d. 854
(Tex App. —Dallas 2006, no pet.) ....................................................... 6
Alvarado v. Farah Mfg. Co., 830 S.W.2d 911
(Tex. 1992) ..................................................................................... 7, 8
Perry Homes v. Cull, 258 S.W. 3d 580
(Tex. 2008) .......................................................................................... 8
Other Page
TEX. R. CIV. P. 193.6 ...........................................................................1-3, 6-8
TEX. R. CIV. P. 193.1 ..................................................................................... 4
TEX. R. CIV. P. 193.6 (b) ............................................................................... 4
Rule 44.4, Tex. R. App. P. .............................................................................. 8
Tex. Tax Code Ann. § 33.47(a) (Vernon 1992) ............................................. 8
Texas Attorney General Opinion No. DM-438, May 2, 1997 ..................... 10
Tex. Tax Code Ann. § 33.05 (Vernon 1992) ............................................... 10
Tex. Tax Code Ann. § 32.03 (Vernon 1992) ............................................... 11
iii
SUMMARY OF REPLY
In Reply to Appellee QUITMAN INDEPENDENT SCHOOL DISTRICT,
WOOD COUNTY, UPPER SABINE WASTE DISPOSAL DISTRICT, AND
WOOD COUNTY CENTRAL HOSPITAL DISTRICT (hereinafter referred to as
either “Appellees” or “Taxing Entities”), Appellants HYDROGEO, LLC AND
FIRST BANK & TRUST EAST TEXAS, (hereinafter referred to as “Hydrogeo”)
offer the following argument.
Regarding Issue number 1 relating to the improperly admitted Exhibit “A”,
Taxing Entities concede the document in question was not produced prior to trial,
and apparently concede their failure to produce violated Texas Rules of Civil
Procedure 193.6. They also acknowledge the plain language of the Rule requires
exclusion, but nevertheless they argue the trial court’s admission of Exhibit “A” was
proper because there was good cause or because its admission did not cause unfair
surprise to Hydrogeo. Appellees’ Brief at 8-10.
Contrary to Taxing Entities’ statements to the trial court and in their Brief,
Exhibit “A” did not consist only of updated tax statements of previously produced
documents. Exhibit “A” contains seven pages, two of which (p. 4 and 7) were never
produced by Taxing Entities. Significantly, those two pages were emphasized by
Taxing Entities during the trial, and in Appellee’s Brief at p.15. Because at least a
portion of the documents was never produced, and because Taxing Entities’
1
intentional withholding of the applicable documents caused Appellants to be at a
disadvantage during trial, Taxing Entities are unable to carry their burden of proving
a lack of unfair surprise.
Along those same lines, Taxing Entities wholly fail to show good cause for
their refusal to supply the documents prior to trial. In order to prevail on this
exception, they must show in the record some legitimate reason explaining their
failure to comply with Rule 193.6. Since Exhibit “A” shows Appellees had these
documents in their possession seventeen days prior to trial, but still chose not to
produce them, good cause does not exist. The improperly admitted Exhibit “A”
constitutes the only evidence offered by Taxing Entities at trial. Without it, their
claims must fail as a matter of law. The trial court’s decision to admit this document
in contravention of Rule 193.6 caused it to render an improper judgment, which
should be reversed and rendered.
Regarding Issue Number 2, Appellees apparently concede they had no right
to foreclose Hydrogeo’s personalty, but argue that since the Judgment forecloses on
only real property, Hydrogeo’s arguments are neither “relevant nor applicable”.
Brief p. 17. Hydrogeo has shown that Taxing Entities are required to tax the
personalty and realty separately, and in this case, should have segregated the portion
of the alleged tax lien which was unenforceable. Contrary to Taxing Entities’
2
representations, they did tax some of Hydrogeo’s personalty, at least according to
their own records.
Since at least a portion of the foreclosed tax lien originates from taxes on
Hydrogeo’s personalty, which apparently Appellees acknowledge was
unenforceable, the trial court was required to segregate that portion of the lien from
the realty. Taxing Entities offered no evidence allowing the trial court to segregate
the lien. The trial court’s decision to render the entire lien enforceable was error.
ARGUMENT
ISSUE NO. 1
Did the trial court commit reversible error by admitting Plaintiffs’
Exhibit “A” into evidence when the document had not been timely produced
prior to trial, and when Taxing Entities failed to show good cause for its failure
to timely supplement discovery responses.
Appellees miss the point of this issue. Part of the disagreement arises from
Taxing Entities’ misunderstanding of their violation of Rule 193.6. Hydrogeo’s
discovery request was not a request for disclosure as referenced in Appellees’ Brief
and as dealt with in the case relied upon by Appellees. Hydrogeo sent a request for
production of documents specifically asking for copies of “each and every tangible
piece of evidence you plan to use at the trial of this cause”. 2 R.R. p. 8, line 21 – p.
9, line 1. A request for disclosure seeks information, not documents. A request for
production seeks specific documents, in this case all documents to be used as
3
evidence at trial. Taxing Entities’ failure to provide these documents negatively
impacted Hydrogeo’s trial preparation and presentation. As stated in Rule 193.1,
“when responding to written discovery, a party must make a complete response,
based on all information reasonably available to the responding party.”
Taxing Entities, without question failed to comply with Rule 193.1 in that they
did not produce the evidence they intended to offer at trial. They admit as much in
their Brief. Additionally, Taxing Entities failed to offer any basis for good cause
explaining why the documents in question were not produced prior to trial, instead
focusing primarily on the defense of lack of unfair surprise. As a reminder, the
burden of establishing lack of unfair surprise rests with Appellees, as the party
offering the discovery, and such proof must be supported by the record. Rule 193.6
(b).
Taxing Entities use as their foundational defense the case of Williams vs.
County of Dallas 194 S.W.3d 29, 33 (Tex. App.—Dallas 2006 pet den’d), a case
distinguishable on several important grounds. First, Williams dealt with a request
for disclosure which only asks for information. Our request required production of
all evidence you intend to offer at trial. Hydrogeo had no way to know ahead of
time what documents Appellees planned to introduce as evidence, or whether
Appellees planned to use any, all or none of the documents previously produced in
discovery. The purpose of generating a request for production such as the one at
4
issue here is to determine what documents will be considered by the Court and to
properly prepare responses, cross examination and rebuttal, if needed, of any
documents presented. By intentionally withholding the requested documents,
Appellees sought, and eventually were allowed, an unfair advantage.
Also, in the Williams case, the trial court conducted an examination
comparing the information offered as evidence with the information previously
produced by the offering party. In our case, the trial court never conducted such an
examination.
By its nature, a failure to produce a document introduced at trial constitutes
some surprise. Appellees argue that their discovery responses, which were
improperly filed with the district clerk, prevent Hydrogeo from being surprised by
the Exhibit “A” which was offered into evidence. Appellees’ Brief at 10-12. There
is no evidence in the record that the trial court had access to, or consulted the district
clerk’s file prior to admitting Exhibit “A”.
Moreover, at least two of the documents, pages 4 and 7 of Exhibit “A”, were
never produced in discovery or as an exhibit to pleadings. Significantly, those two
documents constitute the foundation of Appellees’ argument on appeal, as well as
during the testimony of Carol Taylor, Wood County Tax Assessor. Appellees’ Brief
at 15 and R.R. Volume 2, p. 80, line 4-11 and p.85, line 24 - P. 86, line 6. These two
documents are significant, in that they were used by Taxing Entities to connect
5
Hydrogeo as the record owner of the specific leases in question and as the owner of
specific percentages of the interest involved for the years 2009 - 2011. Appellees’
Brief at 15 and R.R. Volume 2, p. 83, line 21-p. 84, line 5. But for the trial court’s
improper decision to admit pages 4 and 7 of Exhibit “A”, Taxing Entities had no
documentation showing Hydrogeo as the subsequent owner of specific lease I.D.
number N366491 and I.D. number N366493. Since ownership of the lease was a
contested issue, to allow this improper evidence to be admitted led to an improper
judgment. Even if Hydrogeo’s subsequent testimony acknowledged current
ownership, there was no connection of Hydrogeo to the specific tax ID numbers.
Appellees would not have been successful without relying on the rebuttable
presumption created by the introduction of Exhibit “A”.
As stated in Lopez vs. La Madeleine of Texas, Inc., 200 S.W.3d. 854, (Tex
App. —Dallas 2006, no pet.), Rule 193.6 is mandatory and the penalty is automatic,
absent a showing of good cause and/or unfair surprise. Rule 193.6 relates to the
discovery of evidence, not the issues. Its principle purpose is to protect a party from
surprise, whether or not such evidence relates to an issue both parties knew existed
in the case. As the Court stated, “we are concerned not only with whether or not
[Lopez] should have prevailed, but also the effect of opponents’ introduction of the
undisclosed evidence on his preparation for trial and presentation of his case, both
of which were undeniably impacted by the trial court’s decision to admit the
6
evidence.” Id. The Lopez court further states that it is not necessary for the
complaining party to prove that “but for” the exclusion of the evidence, a different
judgment would necessarily have resulted. They are only required to show that the
exclusion of evidence probably resulted in the rendition of an improper judgment.
In short, Appellees failed to show lack of unfair surprise.
GOOD CAUSE DOES NOT EXIST
Appellees also argue there is an “implied” finding of good cause, despite the
plain wording of Rule 193.6 which states that a finding of good cause must be
(explicitly) supported by the record. Appellees’ Brief at 10-12. The Supreme Court
in Alvarado v. Farah Mfg. Co., 830 S.W. 2d 911, 914 (Tex. 1992), states “the good
cause exception permits the trial court to excuse a failure to comply with discovery
in difficult or impossible circumstances” (emphasis added). The Rule as
interpreted by the Supreme Court requires Taxing Entities to offer evidence as to
why complying with the Rule was difficult or impossible. A review of Exhibit “A”
shows the documents were generated and printed on “August 22, 2014 at 11:43
a.m.”. Appendix A. Since the trial did not take place until September 8th, the
documents themselves prove they existed and were in the Taxing Entities’
possession seventeen days prior to trial. Therefore any attempt to show good cause
rings hollow.
7
COURT’S ERROR CAUSED IMPROPER JUDGMENT
Pursuant to Rule 44.4, Texas Rules of Appellant Procedure, no judgment may
be reversed on appeal unless the error complained of probably caused rendition of
an improper judgment. Appellee argues there was testimony to support the
Judgment, even if Exhibit “A” had not been admitted. Appellees’ Brief at 15.
Contrary to Appellees’ argument, all of the testimony cited was simply the tax
assessor reading Exhibit “A” itself verbatim. R.R. Volume 2, p. 79, line 8 – 13; p.
80, line 4-11; and p. 85, line 24-p.86, line 6. Simply stated, Taxing Entities must
stand or fall on the information and alleged presumption represented by the
documents referred to as Exhibit “A”. If they were improperly admitted, their case
fails due to a lack of any evidence to support the trial court’s judgment.
The test is whether the trial court acted without reference to any guiding rules
or principals, or arbitrarily or unreasonably. Perry Homes v. Cull, 258 S.W. 3d 580,
602 (Tex. 2008). As stated by the Supreme Court in Alvarado, Rule 193.6 is
mandatory and the trial court has no discretion to admit testimony excluded by the
Rule without a showing of good cause. Id. Since there was no other admissible
evidence offered at trial by Taxing Entities, and the Exhibit “A” described herein
should not have been admitted, and the testimony of Ms. Taylor was simply
recitation of the data referenced in Exhibit “A”, the Taxing Entities are not entitled
to the legal presumption created by Section 33.47(a) Tax Code. Therefore, there is
8
no evidence to support the trial court’s judgment in favor of the Taxing Entities. As
such, the trial court’s judgment should be reversed and rendered.
ISSUE NO. 2
Did the trial court err by holding Taxing Entities’ entire alleged tax lien
enforceable against Hydrogeo, LLC, and First Bank & Trust East Texas when
Taxing Entities failed to segregate that portion of the lien which was
unenforceable against Hydrogeo.
TAXES WERE ASSESSED ON BOTH REAL
AND PERSONAL PROPERTY
It should be pointed out that if this Court of Appeals upholds Appellants’
position on Issue No. 1, then this issue becomes moot because the only evidence
offered by Taxing Entities attempting to prove their case comes from either the
improperly admitted Exhibit “A” or from witnesses reading information from
Exhibit “A”.
Appellees concede in their Brief they had no right to foreclose on Hydrogeo’s
personalty, but argue that no personalty was included in this lawsuit and foreclosure.
Appellees’ Brief at 16-17. Taxing Entities misunderstand how oil and gas properties
are described. A description of the leasehold estate as mentioned in Plaintiffs’
Second Amended Petition includes oil and gas in place, but also includes the
personalty necessary to produce, store and transport the oil and gas. C.R. Volume 3
9
Exhibit #1. The Black Diamond Exhibit 1 is an assignment describing the leases in
question, and states that the lease includes “all tangible personalty, property,
equipment, …” Id.
As stated in a 1997 Texas Attorney General Opinion, “irrespective of whether
production equipment is real or personal property it must be appraised separately
from its corresponding mineral leasehold interest. Opinion No. DM-438, May 2,
1997. As the Opinion also recognizes, the classification of property as real or
personal is material to such matters as the statute of limitations because the statute
treats real and personal property differently. Texas Tax Code Annotated §33.05
(Vernon 1992).
Contrary to their Brief, Taxing Entities did appraise and tax at least some of
the personal property existing on the leases made the basis of this lawsuit. According
to its 2011 Tax Statement (C.R. Vol. 3, Exhibit HB-10), the I.E. Robinson Lease is
appraised at $340,070. A review of C.R. Vol. 1, page 137, which is Pritchard and
Abbott’s appraisal sheet for the year 2011 on the I.E. Robinson Lease, the appraised
value for the leasehold shows a specific amount credited to “equipment value”,
which constitutes a part of the $340,070 total appraised value. In other words, at
least a portion of the appraised value upon which the taxes were rendered on the I.E.
Robinson Lease, and upon which the Taxing Entities rely for their tax lien, comes
from the personalty.
10
While the actual appraised amount for the equipment is not determinative, it
is evidence in the record disputing Taxing Entities’ claim that they did not tax or
foreclose on Hydrogeo’s personalty. Assuming a portion of the alleged tax lien
consisted of taxes for personalty, it was incumbent on Taxing Entities to segregate
that portion of the alleged lien that was unenforceable. Since they made no attempt
to distinguish between the enforceable part and the unenforceable part, the trial court
had no evidence to support a judgment allowing foreclosure of the entire tax lien.
In our case, Hydrogeo, because of the undisputed evidence offered at trial, is
exempt from having any lien foreclosed on its personalty. Tex. Tax Code Ann.
§32.03, (Vernon 1992). Since Hydrogeo filed a verified denial contesting ownership
of the property during the applicable years in question and questioning the
sufficiency of the lien on the property, both real and personal, the burden of proof to
plead and prove all the elements of Taxing Entities’ claims shifted to them.
For the reasons shown in Appellants’ Brief, Taxing Entities were required to
prove how much of their underlying tax lien was enforceable. Since the amount of
the debt was not proved, the underlying lien which was supported by the debt failed
also. The burden of proof belonged to Taxing Entities as plaintiffs and they failed to
carry the burden. Thus, it was error for the trial court to hold that the entire tax lien
was enforceable.
11
CONCLUSION
As shown herein, the one piece of evidence offered by Taxing Entities was
improperly admitted because it had not been provided to opponents prior to trial and
because no effort was made by Taxing Entities to prove good cause allowing its
admission. By definition, as the one document proffered by Taxing Entities, the trial
court’s error was harmful. The only document relied upon by Taxing Entities was
improperly admitted.
Even if it should have had been admitted, Exhibit “A” failed to segregate the
amount of taxes assessed for personalty. Segregating the portion of taxes assessed
for personalty was essential because the amount of the tax lien was unenforceable
against a buyer in the ordinary course of business, such as Hydrogeo. The evidence
cannot support Taxing Entities’ desire to foreclose on the entire claimed lien on the
two oil and gas leases in question. The trial court’s judgment therefore should be
reversed and rendered.
PRAYER
Wherefore premises considered, the Court should reverse the trial court’s
judgment, and render judgment in favor of Appellants Hydrogeo, LLC and First
Bank and Trust East Texas and hold that the Taxing Entities take nothing against
Appellants.
12
Respectfully submitted,
/s/ J. Don Westbrook
J. Don Westbrook
Texas Bar No. 21215500
COGHLAN CROWSON, L.L.P.
1127 Judson Road, Ste. 211
Longview, Texas 75605
(903) 758-5543
(903) 753-6989 Facsimile
email: dwestbrook@ccfww.com
Attorneys for Appellants Hydrogeo, LLC
and First Bank & Trust East Texas
CERTIFICATE OF COMPLIANCE
Counsel certifies that this reply brief contains, as counted by Microsoft Word,
2934 words. It was typed in 14-point Times New Roman.
Dated: August 11, 2015
/s/ J. Don Westbrook
J. Don Westbrook
13
CERTIFICATE OF SERVICE
I hereby certify that the above and foregoing Reply Brief of Appellants has
been served on all counsel of record in this appeal in accordance with the Texas
Rules of Appellate Procedure on August 11, 2015.
/s/ J. Don Westbrook
J. Don Westbrook
14
Index of Appendices
A. Plaintiffs’ Exhibit “A”, Certified Copy of Tax Records, dated August 22,
2014 (7 pages).
15
Appendix A
..
CERTIFIED COPY OF TAX RECORDS
FOR
QUITMAN INDEPENDENT SCHOOL DISTRICT, WOOD COUNTY, UPPER SABINE
WASTE DISPOSAL DISTRICT AND WOOD COUNTY CENTRAL HOSPITAL DISTRICT
SUIT NO. T-3625
QUITMAN INDEPENDENT SCHOOL DISTRICT, ET AL VS. BLACK DIAMOND
OPERATING CO LLC, ET AL
THE STATE OF TEXAS x
WOOD COUNTY x
I hereby certify that the following exhibit (ensuing page(s)) is a true and correct copy of entries in the
tax records of my office. The penalty and interest amounts were calculated according to Section 33.01
and 33.07 of the Texas Property Tax Code.
r..&l
In testimony whereof, witness my hand and seal of office this O? ~ day of_-'~~_,,'--"='----'
20.l!f__.
Carol Taylor
Tax Assessor-Collector and Custodian of the Tax
Records for: QUITMAN INDEPENDENT
SCHOOL DIS1RICT, WOOD COUNTY, UPPER
SABINE WASTE DISPOSAL DIS1RICT and
WOOD COUNTY CENTRAL HOSPITAL
DIS1RICT
EXHIBIT "A"
Suit No. T-3625 Suit Key No. 2137912
Account Summary
Carol Taylor, Tax Collector
Wood County Tax Office
P.O. BOX 1919
Quitman, TX 75783
Ph: (903)763-2261 Fax: (903)763-5753
Property: 0154550-0001055-5-RI
Quick Ref ID: N355851
Owner: BLACK DIAMOND OPERATING CO LLC
Legal Description: 0.833335 0154550 WHITE DENTON BLACK
DIAMOND OPER RI (ROYALTY INTERESl)
BLACK DIAMOND OPERATING CO LLC
4420 VALLEY RANCH RD
LONGVIEW, TX 75602-6671
Tax Bill (Effective Date: 09/15/2014) Balance Due if Paid By September 30, 2014: 29,131.29
Bill Levy Disc/Credi
Levy Balance P & I Atty Fees t Date Paid Amt Paid Balance
2009
Quitman lsd 10,679.32 10,305.12 7,082.29 2,664.25 0.00 09/2212010 516.38 19,909.48
Waste Disposal District 169.36 163.42 112.33 42.24 0.00 09/2212010 8.20 315.73
Wood county 4,375.23 4,221.93 2,901.57 1,455.37 0.00 09/2212010 220.76 8,511.41
yyao~. ~unty Central 211.70 204.28 140.39 52.82 0.00 09/2212010 10.24 394.67
Totals 15,435.61 14,894.75 10,236.58 4,214.68 0.00 755.58 29,131.29
Totals 15,435.61 14,894.75 10,236.58 4,214.68 0.00 755.58 29,131.29
Balance Due if Paid By September 30, 2014: 29,131.29
Pay By Total Due
October 31, 2014 29,304.68
November 30, 2014 29,478.09
December 31, 2014 29,651.50
PrintedonB/2212014 11:43AM Page 1 of 1
Account Summary
Carol Taylor, Tax Collector
Wood County Tax Office
P.O. BOX 1919
Quitman, TX 75783
Ph: {903)763-2261 Fax: (903)763-5753
Property: 0154550-0715543-WI
Quick Ref ID: N357528
Owner: RHEATA RESOURCES LLC
Legal Description: 0.833335 0154550 WHITE DENTON BLACK
DIAMOND OPER WI
RHEATA RESOURCES LLC
PO BOX921
KILGORE, TX 75663
Tax Bill (Effective Date: 09/10/2014) Balance Due if Paid By September 30, 2014: 22,099.47
Bill Levy Disc/Credi
Levy Balance P&I Atty Fees t Date Paid Amt Paid Balance
2010
Quitman lsd 5,309.68 5,309.68 2,973.42 1.242.47 0.00 0.00 9,525.57
Waste Disposal District 89.10 89.10 49.89 20.85 0.00 0.00 159.84
Wood County 2,415.20 2.415.20 1,352.51 753.54 0.00 0.00 4,521.25
~oo_~. saunty Central 104.58 104.58 58.57 24.47 0.00 0.00 187.62
Totals 7,918.56 7,918.56 4,434.39 2,041.33 0.00 0.00 14,394.28
2011
Quitman lsd 3,070.38 3,070.38 1,350.97 663.20 0.00 0.00 5,084.55
waste Disposal District 53.48 53.48 23.53 11.55 0.00 0.00 88.56
Wood County 1,405.18 1,405.18 618.28 404.69 0.00 0.00 2,428.15
........
Wood County Central
Totals
62.76
4,591.80
62.76
4,591.80
27.61
2,020.39
13.56
1,093.00
0.00
0.00
0.00
0.00
103.93
7,705.19
Totals 12,510.36 12,510.36 6,454.78 3,134.33 0.00 0.00 22,099.47
Balance Due if Paid By September 30, 2014: 22,099.47
Pay By Total Due
October 31, 2014 22,245.25
November 30, 2014 22,391.03
December 31, 2014 22,536.79
Printedon8/22/2014 11:44AM Page 1 of 1
Account Summary
Carol Taylor, Tax Collector
Wood County Tax Office
P.O. BOX 1919
Quitman, TX 75783
Ph: (903)763-2261 Fax: (903)763-5753
Property: 0154550-0716237-WI
Quick Ref ID: N366493
ONner. HYDROGEO LLC
legal Description: 0.833335 0154550 WHITE DENTON HYDROGEO
LLCWI
HYDROGEO LLC
PO BOX 921
KILGORE, TX 75663
Tax Bill (Effective Date: 08/22/2014) Balance Due if Paid By August 31, 2014: 0.00
Bill Levy Disc/Credi
Levy Balance P & I Atty Fees t Date Paid Amt Paid Balance
2012
Quitman lsd 473.88 0.00 0.00 0.00 0.00 01/03/2013 473.88 0.00
Waste Disposal District 8.12 0.00 0.00 0.00 0.00 01/03/2013 8.12 0.00
Wood County 213.14 0.00 0.00 0.00 0.00 01/0312013 213.14 0.00
yyood. sounty Central 8.88 0.00 0.00 0.00 0.00 01/0312013 8.88 0.00
Totals 704.02 o.oo 0.00 0.00 o.oo 704.02 0.00
2013
Quitman lsd 3,086.91 0.00 0.00 0.00 0.00 02/06/2014 3,086.91 0.00
Waste Disposal District 53.67 0.00 0.00 0.00 0.00 02/06/2014 53.67 0.00
Wood County 1,394.67 0.00 0.00 0.00 0.00 02/0612014 1,394.67 0.00
Wood County Central 56.18 0.00 0.00 0.00 0.00 02/06/2014 56.18 0.00
" .......
Totals 4,591.43 0.00 0.00 0.00 0.00 '. 4,591.43 0.00
Totals 5,295.45 0.00 0.00 0.00 0.00 5,295.45 0.00
Balance Due if Paid By August 31, 2014: 0.00
Printed on 8122/2014 11:44 AM Page 1 of 1
Account Summary
Carol Taylor, Tax Collector
Wood County Tax Office
P.O. BOX 1919
Quitman, TX 75783
Ph: (903)763-2261 Fax: (903)763-5753
Property: 0133400.0713907-WI
Quick Ref ID: N310883
Owner. BLACK DIAMOND OPERATING CO LLC
legal Description: 0.875000 0133400 ROBINSON IE BLACK
DIAMOND OPER WI
BLACK DIAMOND OPERATING CO LLC
4420 VALLEY RANCH RD
LONGVIEW, TX 75602-6671
Tax Bill (Effective Date: 09/23/2014) Balance Due if Paid By September 30, 2014: 9,423.15
Bill levy Disc/Credi
Levy Balance P&I Atty Fees t Date Paid Amt Paid Balance
2007
Quitman lsd 5,187.91 0.00 933.82 918.26 0.00 0712212008 7,039.99 0.00
Waste Disposal District 77.36 0.00 18.84 14.41 0.00 0512112009 110.61 0.00
Wood County 2,138.87 0.00 520.67 531.91 0.00 05/2112009 3,191.45 0.00
~od. c,ounty Central 112.40 0.00 27.35 20.98 0.00 05/21/2009 160.73 0.00
Totafs 7,516.54 0.00 1,500.68 1,485.56 0.00 10,502.78 0.00
2008
Quitman lsd 92.43 0.00 12.02 0.00 0.00 05121/2009 104.45 0.00
Waste Disposal District 1.32 0.00 0.17 0.00 0.00 05/21/2009 1.49 0.00
Wood County 37:17 0.00 4.83· 0.00 0.00 05/21/2009 42.00 0.00
Wood County Central 1.78 0.00 0.23 0.00 0.00 05121/2009 2.01 0.00
" .......
Totals 132.70 0.00 17.25 0.00 0.00 149.95 0.00
2009
Quitman lsd 3,704.18 3,333.42 2,338.38 906.37 0.00 09/2212010 508.76 6,440.17
Waste Disposal District 58.74 52.86 37.07 14.37 0.00 0912212010 8.06 102.12
Wood County 1,517.57 1,365.67 958.02 495.12 0.00 0912212010 217.51 2,753.20
~oOO.. c,ounty Central 73.43 66.08 46.35 17.97 0.00 09/22/2010 10.09 127.66
Totals 5,353.92 4,818.03 3,379.82 1,433.83 o.oo 744.42 9,423.15
Totals 13,003.16 4,818.03 4,897.75 2,919.39 0.00 11,397.15 9,423.15
Balance Due if Paid By September 30, 2014: 9,423.15
Pay By Total Due
October 31, 2014 9,479.25
November 30, 2014 9,535.33
December31,2014 9,591.43
Printed on 8/22/2014 11:42 AM Page 1 of 1
..
Account Summary
Carol Taylor, Tax Collector
Wood County Tax Office
P.O. BOX 1919
Quitman, TX 75783
Ph: (903)763-2261 Fax: (903)763-5753
Property: 0133400-0715543-VVI
Quick Ref ID: N357525
owner: RHEATA RESOURCES LLC
Legal Description: 0.875000 0133400 ROBINSON IE BLACK
DIAMOND OPER WI
RHEATA RESOURCES LLC
PO BOX921
KILGORE, TX 75663
Tax Bill (Effective Date: 09/10/2014) Balance Due if Paid By September 30, 2014: 21,750.06
Bill Levy Disc/Credi
Levy Balance P&I Atty Fees t Date Paid Amt Paid Balance
2010
Quitman lsd 4,480.57 4,480.57 2,509.11 1,048.45 0.00 0.00 8,038.13
Waste Disposal District 75.19 75.19 42.10 17.59 0.00 0.00 134.88
Wood County 2,038.06 2,038.06 1,141,32 635.88 0.00 0.00 3,815.26
'!'!".°":.~aunty Central 88.25 88.25 49.42 20.65 0.00 0.00 158.32
Totals 6,682.07 6,682.Ql 3,741.95 1,722.57 0.00 0.00 12,146.59
2011
Quitman lsd 3,826.81 3,826.81 1,683.80 826.59 0.00 0.00 6,337.20
Waste Disposal District 66.65 66.65 29.33 14.40 0.00 0.00 110.38
Wocx! County 1,751.36 1,751.36 no.60 504.39 0.00 0.00 3,026:35
'f'!".od. ~unty Central 78.22 78.22 34.42 16.90 0.00 0.00 129.54
Totals 5,723.04 5,723,04 2,518.15 1,362.28 o.oo 0.00 9,603.47
Totals 12,405.11 12,405.11 6,260.10 3,084.85 0.00 0.00 21,750.06
Balance Due if Paid By September 30, 2014: 21,750.06
Pay By Total Due
October 31, 2014 21,894.61
November 30, 2014 22,039.17
December 31, 2014 22,183.73
Printed on 812212014 11:42 AM Page 1 of 1
..
Account Summary
Carol Taylor, Tax Collector
Wood County Tax Office
P.O. BOX 1919
Quitman, TX 75783
Ph: (903)763-2261 Fax: (903)763-5753
Property: 0133400-0716237-WI
Quick Ref ID: N366491
Owner: HYDROGEO LLC
Legal Description: 0.875000 0133400 ROBINSON I E HYDROGEO
LLCWI
HYDROGEO LLC
POBOX921
KILGORE, TX 75663
Tax Bill (Effective Date: 08/2212014) Balance Due if Paid By August 31, 2014: 0.00
Bill Levy Disc/Credi
Levy Balance P & I Atty Fees t Date Paid Amt Paid Balance
2012
Quitman lsd 1,376.69 0.00 0.00 0.00 0.00 01/03/2013 1,376.6~ 0.00
Waste Disposal District 23.58 0.00 0.00 0.00 0.00 01103/2013 23.58 0.00
Wood County 619.20 0.00 0.00 0.00 0.00 01/03/2013 619.20 0.00
y:ro_o~. scunty Central 25.81 0.00 O.DD 0.00 0.DD 01/03/2013 25.81 0.00
Totals 2,045.28 0.00 0.00 0.00 0.00 2,045.28 o.oo
2013
Quitman lsd 4,142.30 0.DD 0.00 0.00 0.00 02106/2014 4,142.30 0.00
Waste Disposal District 72.02 0.00 0.00 0.DD 0.00 02/06/2014 72.02 0.00
Wood County 1,871.50 0.00 0.00 0.00 0.00 02/06/2014 1,871.50 O.DD
~"Hydrogeo, LLC, First Bank & Trust East Texas v. Quitman Independent School District
Combined Opinion