in the Interest of K.T. and R.D.T., Children

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