Filed: 6/8/2015 1:07:17 PM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 5582618
By: Sara Redmond
6/8/2015 1:19:37 PM
NO. 07FD2827
IN THE INTEREST OF § IN THE COUNTY COURT AT LAW
§
KERISSA TOUCHSTONE AND § NUMBER TWO
RICHARD DALE TOUCHSTONE §
§
CHILDREN § GALVESTON COUNTY, TEXAS
RESPONDENT'S AFFIDAVIT OF INABILITY TO PAY COSTS OF APPEAL
STATE OF TEXAS §
GALVESTON COUNTY §
Before me, the undersigned notary, on this day personally appeared Elisa Marie Moreno, a person
whose identity is known to me. After I administered an oath to her, upon her oath she said the following:
1
1. "My name is lisa Marie Moreno, and I am the Respondent in this case. I am of sound
mind and capable of making his affidavit. The facts stated within this affidavit are within my personal
knowledge and are true and c rrect.
2. "On March 10 2015, the trial court signed a final Order in favor of Petitioner and against
me in Cause Number 07FD28 7. After a timely Motion for New Trial was filed by the Attorney General's
Office, the Court signed an Or er Modifying the Judgment on May 15, 2015. I intend to appeal the court's
final judgment to the 1st or 14th Court of Appeals in Houston.
3. "The estimate cost of the reporter's record is $522.50. I am unsure of the cost of the
clerk's record.
4. "I am unable t pay any of the court costs of the appeal.
5. "I have been nemployed since February 1, 2015. I collect unemployment income of $251
weekly. I have no other incom from any other source. See exhibit 1 and incorporate by reference.
6 "I do not have a spouse.
7 "I have four (4 dependents, who are my children and who I am obligated to support. Two
of them live with me, Eleazar Pena who is 17 and Joshua Pena who is 15. Two of them, Kerissa and
Richard Touchstone, I am obi gated to support per this Court's order at $384 monthly plus an additional
$50 monthly in medical suppo
8. "I do not own ny real or personal property.
9. "I have no ca h and no money on deposit.
10. "I do own a vrhicle, a 1997 Chevy Lumina, which is worth about $500. I have no other
assets.
I
11. "My monthly expenses are: approximately $2000, and that includes $500 monthly rent,
$400 in food and supplies, $300 in utilities and telephone, $100 in clothing and laundry, $80 car insurance,
$150 in gas and repairs, plus the $384 and $50 ordered by this Court for Child support. My total monthly
income is only $1132, and that includes the food stamps.
12. "I am not able to obtain a loan to payfor the costs of the appeal as I have already reached
my maximum limit for borrowing from all known sources including friends and family.
13. "I am represented by legal counsel, who is providing services to me for free on this appeal,
but she cannot or will not pay the costs of the appeal.
14. "I am currently receiving public benefits, including Food Stamps and CHIP. I receive $45
monthly in food stamps. See exhibits 2 and 3, attached and incorporate by reference.
15. "I have neither the access to the equipment necessary nor the skill necessary to prepare
the appendix.
16. "Further affiant sayeth not."
~h1·bbwtr
ELISA MARIE MORENO
•• iw£Xi!,w,aAA,~Iib«R.q~ me by Elisa Mari~ roreno on June 8, 2015.
• .
m::;: E
STATE OF TEXASlftuE
/J IJjl~ rJvJLiL t. (!nil
r:t&ary Public in and for ---->0<->..-_-
, - Comm. Exp. 02.20-~ The State of Texas
CERTIFICATE OF SERVICE
I certify that true a copy of the above was served on each attorney of record or party by a method
permitted by Rule 21a of the Texas Rules of Civil p~une~
, JULIA C. HATCHER
2
1887 1391-1 C18666
STATEMENT OF BENEFITS
TEXAS WORKFORCE COMMISSION
PO BOX 2211
UJ
F\)
0
.I>-
-
=
==
MC ALLEN TX 78502-2211 0
UJ
Statement of Wages and Potential Benefit Amounts OJ iiiiiiiiiiii
-
0
Regular Unemployment Benefits: ~ iiiiiiiiiiii
Date Mailed: February 5, 2015 co --
CD
-..j =
~
(All dates are in month/day/year order) ~
0
0
cw
=
=
ELISA M MORENO
14804 GAMBLE RD
SANTA FE TX 77517-3166
11'1111'111.1.1 •••• 11I••• 1•• 11'11.11.11 ••• 11••11,,"1 •• 1•• 11.1
Social Security Number: XXX-XX-7070
Dear ELISA M MORENO
Check your records! TWC has the wages below on file for you for the four quarters of your base
period. We use your base period wages to figure out whether you earned enough money to qualify for
unemployment insurance benefits and how much you could receive if you are eligible. After TWC looks
at whether you earned enough money to qualify, TWC looks at the reason you are no longer working to
decide whether you can receive bene·fits. Remember, even if you earned enough wages, TWC pays
benefits only if you meet the weekly requirements.
Please check the wage information carefully. If the employer name or the wage amount is incorrect, or
if an employer you worked for is missing, please contact a TWC Tele-Center immediately. More
information about correcting your wages is on the back of this form.
Based on the wages listed in the box below:
[Xl You earned enough in your base period to 0 You did not earn enough in your base
receive unemployment benefits. if you are period to qualify for benefits.
otherwise E!ligible. i
i
Oct-Dee 2013 ~an-Mar 2014 Apr-Jun 2014 Jul-Sep 2014
FLUOR DANIEL SERVICES TX
FAMI LY DOLLAR STO~!ES OF TEXAS
SAFWAY SERVICES LLC
LLC I. TX
TX
0.00
0.00
0.00
0.00
2,933.44
0.00
0.00
1,361.44
4,914.00
5,803.13
0.00
0.00
5,803.13
4.294.88
4,914.00
'* You will receive a separate notice explaining why we did not use these wages.
The maximum weekly benefit amount in Texas this year is $ 465. Based on the wages above,
your weekly benefit amount is $ 251 .
The maximum amount you could receive during your benefit year is s ...,;4;.;:0;.;:5...;.4
__ .
Your benefit year is the 52 weeks from 02-01-15 to 01-30-16
Keep in mind your benefits may run out before the benefit year ends.
See the back of this page for more information.
Claim 10.: 02-{)l-15
TWC Tale-phono No.: (&00)939-6631
FOR HEARING IMPAIRED CLIENTS
Relay Texas TOO No.: 1-800-735-2989
Voice No.: 1-800-735-2988
BM100E 12/12/07
Form TF0001
August 2014
HHSC - MIDLAND
PO BOX 14900
MIDLAND TX 79711-4900
~,TEXAS
~ ~_I. . Heattth and Human;
••• ( SewicesCommissron
Date: 03/23/2015
Need help?
Case Number: 1010526287
Call 2-1-1 or 1-877-541-7905
If you have a hearing or speech disability,
call 7-1-1 or any relay service.
All numbers are free to call.
ELISA MARIE MORENO
14804 GAMBLE RD
SANTA FE TX 77517
Notice about your case:
SNAP Food Benefits
EDG number: 101496605
Who gets SNAP Food Benefits
Name Date Monthly Amount
Eleazar Pena Jr; Joshua Pena; Elisa Marie
Moreno
03/01/2015 - 07/31/2015 $ 45.00
Elisa Marie Moreno; Joshua Pena; Eleazar Pena
Jr
02/20/2015 - 02/28/2015 $ 93.00
Who can't get SNAP Food Benefits
Name Date
Richard Dale Touchstone III; Kerissa Renae Touchstone 02/20/2015
Notes:
Kerissa Renae Touchstone can't be part of this benefits case. - (TW A-231 , 1 TAC 372.151; 372.152;
372.153; 372.1508, 7 CFR 273.1 )
Richard Dale Touchstone III can't be part of this benefits case. - (TW A-231 , 1 TAC 372.151; 372.152;
372.153; 372.1508, 7 CFR 273.1 )
Health Care Benefits
.
Page 1 of 3
3769
Form TF0001
August 2014
W'ho gets health care benefits
Name EDG number Program Date
Children's Health
05/01/2015 -
Eleazar Pena Jr 631863789 Insurance Program
10/31/2015
(CHIP)
Children's Health
05/01/2015 -
Joshua Pena 631863790 Insurance Program
10/31/2015
(CHIP)
Who can't get health care benefits
Name EDG Number Program Date
Eleazar Pena Jr 637885791 Children's Medicaid 02/01/2015
Reason:
You are not eligible for benefits. -(TWA-2350, 1 TAC 366.215; 366.311; 366.409; 366.511; 366.615;
366.711; 366.811; 366.903, 42 CFR 435.919)
(Joshua Pena, Eleazar Pena Jr) isn't: (1) age 20 or younger, (2) age 65 or older, (3) pregnant, (4)
someone with a disability, (5) a dependent child on this case, OR (6) a child who didn't get SSI
(Supplemental Security Income) due to the August 1996 change in disability rules. - (TW A-825; A-221B
475.1.2, 1 TAC 366.307; 366.507; 366.611; 366.707; 366.807, 42 CFR 435.301)
Page 2 of 3 3770