In the Fourth Court Of Appeals Fourth Court Of Appeals District 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 To The Fourth Court of Justices In Appeals Court STATEMENT FROM APPELLANT MARYANN CASTRO MOTION TO ACCEPT FINAL CLOSING ARGUMENT AS TO WHY THE AGREEMENT FOR FINAL DIVORCE SIGNED OCT 30,2013 SHOULD BE MODIFIED,AMENDED EVEN VOIDED AND REWRITTEN REOPENED TO A JUST AND RIGHT DIVORCE DECREE DUE TO THE FOLLOWING MISREPRESENTATION,FRAUD THAT OCCURED IN THE AGREEMENT FOR FINAL DIVORCE AGREEMENT SIGNED OCT 30,2013 THE FRAUD WAS DISCOVERED AFTER THE DATE OF OCT 30,2013 OPINION (see copy of Agreement) #1 This is an appeal from a final decree of divorce in which wife challenges the Agreement for Final Divorce signed Oct30, 2013.Appellee Manuel Castro and Appellant Maryann Castro have been before the Court. The Courts JUDGES never heard the actual facts in the Marriage of Manuel AND Maryann Castro or even read documents showing the facts as to why the Agreement for Final Divorce should be reopened, modified ,amended rewritten even voided, the ORIGINAL agreement was NEVER filed it was tampered ,a copy was filed by Counsel Joseph Appelt who participated with his client Appellee Manuel Castro in fraud, hiding martial asset, prejudice of Appellant Maryann Castro disability the agreement has fraud bankruptcy, non-payment of mortgage, overvalued martial home, hiding martial assets even Adultery, Cruelty. The Trial Court Judges erred in not voiding the Agreement for Final Divorce(lf the Spouse seeking post judgement relief longstreet v longstreet, 57 ohio app.3d 55,566 N.E.2d 708 (1989) husband value home at 50,000 but sold it 14 months later for 79,000.(Salem V. Salem, 610hio App. 3d 243,572,N.E. 2d 726 (1988)wife made conclusory allegations of nondisclosed assets, citing a news paper article as her only basis for suspecting fraud) The time period for a motion to reopen a judgement is tolled by the automatic stay imposed (A party seeking to reopen a judgement has an obligation to act with reasonable diligence after learning relevant facts. E.G., In re Gidlund,244 III..App.3d 675,614 N.E. 2d 315(1993)The law of reopening judgements should be changed so that when one spouse commits deliberate and malicious fraud ,and the other spouse was unable through due diligence to detect the fraud, there is no time limit ori the courts power to grant effective relief. BACKGROUND FACTS Martial fraud on the Community estate, Appellant Maryann Castro is the innocent spouse in this divorce fraud in the Communitywas committed by Appellee Manuel Castro and Counsel Joseph Appelt by committing the following if there were no property then the lift stay does not need to be filed there was 1501 Olive and the lift stay was not filed on Oct 30,2013 that isaviolation of family and bankruptcy law Appellant Maryann Castro did not know Appellee Manuel Castro hadthe subject property 1501 Olive in active bankruptcy and was not making the home mortgage payments. A) APPELLEE MANUEL CASTRO FILED BANKRUPTCY WITHOUT NOTIFYING THE COURT OR APPROVAL OF THE COURT AND DID NOT NOTIFY APPELLANT MARYANN CASTRO THE BANKRUPTCY APPELLEE MANUEL CASTRO FILED WAS ACTIVE ON OCT 30,2013 AND STAY LIFT NOT FILED OR APPROVED BY THE BANKRUPTCY COURT IN ORDER TO PROCEED IN THE DIVORCE APPELLEE MANUEL CASTRO WAS ADVISED BY THE TRUSTEE AND HE DID NOT NOTIFY THE COURT AND STILL PROCEEDED TO HARM APPELLANT MARYANN CASTRO ANDlTOT, THE COURT^OW THE TRUTH ON OCT 30,2013 ftO(L HT^Uj-^nn Cft^ftO A^p/Z^n^ APPELLEE MANUEL CASTRO HAD NOT PAYED THE HOMEMORTGAGE HAD UNPAID ARREARS AND IN HIS BANKRUPTCY PLAN THAT WAS BEING PAYROLL DEDUCTED IN THE PLAN THE MORTGAGE HAD TO BE PAID TOO AND THAT WAS NOT BEING PAID HIS COUNSEL JOSEPH APPELT LIED TO ALL JUDGES IN PRESIDING SAYING IT WAS DISCUSSED AND NOTED IT NEVER WAS APPELLEE MANUEL CASTRO AGREED TO PAY THE MORTGAGE ON OR ABOUT OCT 2011 WHEN THE ACTUAL FILING FOR DIVORCE BEGAN AND IT WAS TO BE PAID IN HIS BANKRUPTCY PLAN AND HE DID NOT FOLLOW THE PLAN HE AGREED TO WHEN HE FILED BANKRUPTCY. B) WRIGHT VS WRIGHT NO. 11-07-00169-CV FRAUD ON THE COMMUNITY ^ APPELLEE MANUEL CASTRO WITH COUNSEL JOSEPH APPELTTURNED OVE#THE COURTA COMPARATIVE MARKET ANALYSIS A REALTORS OPINION TO OVER VALUE THE COMMUNITY 1501 OLIVE AT 125,000 TO GAIN FRAUD EQUITY AT 40,000 WHEN THE COMMUNITY 1501 OLIVE DOES NOT HAVE EQUITY IT HAS ARREARS FROM BANKRUPTCY FILED BY APPELLEE MANUEL CASTRO NONPAYMENTS OF MORTGAGE SEE BSI STATEMENT IFTHE COMMUNITY 1501 OLIVE ST GOES INTO FORECLOSURE THERE WILL BE A NEGETIVE AMOUNT OWED IN THE AMOUNT OF 60,000 APPELLANT MARYANN CASTRO HAS RETAINED ATTORNEY MATTHEW OBREMEIER TO PROTECT HER INTEREST IN THE MARTIAL HOME 1501 OLIVE ST WHERE SHE RESIDES AT HER HOMESTEAD APPELLANTMARYANN CASTRO WAS AWARDED THE HOME ON OCT 30,2013 WITH TERMS BUT DID NOT KNOW THE MARTIAL HOME WAS IN ACTIVE BANKRUPTCY FILEMPPELLLEE MANUEL CASTRO COUNSEL JOSEPH APPELT KNEW OF THE BANKRUPTCY AND THAT THE AUTOMATIC STAY LIFT WAS NOT FILED BY APPELLEE MANUEL CASTRO AND TRUSTEE DID ADVISE THIS WAS NEEDED TO BE DONE IN/ORDER TO PROCEED IN THE DIVORCE AND IT WAS IGNORED AND NOT DONE" COUNSEL JOSEPH APPELLT KNEW THIS AND AS AN OFFICER OF THE COURT STILL PROCEEDED IN THE DIVORCE AND AGREEMENT KNOWNG THE HARM THAT WAS BROUGHT UPON APPELLANT MARYANN CASTRO WHEN IN BANKRUPTCY THE PERSON WHO FILED HAS TO CLEAR WITH THE COURT TO PROCEED IN DIVORCE AND THIS WAS NOt DONE BY APPELLEE MANUEL CASTRO AND COUNSEL JOSEH APPELLT KNEW THIS AND DID NOT FOLLOW THE TRUSTEE ADVISE ONLY TO HARM APPELLANT MARYANN CASTRO WITH AN AGREEMENT THAT WAS NOT CLEARED THROUGH THE BANKRUPTCY COURT APPELLEE MANUEL CASTRO OWED A HIGH DOLLAR AMOUNT AND WAS NOT PAYING THE MORTGAGE THE AGREEMENT IS NOT VALID IT WAS PREPARED UNDER FALSE , MISREPRESENTATION IT CHANGES EVERTHING APPELLEE MANUEL CASTRO DID NOT HAVE PERMISSION FROM THE BANKRUPTCY COURT TO PROCEED IN THE AGREEMENT FOR FINAL DIVORCE HIS BANKRUPTCY WAS ACTIVE AND THE COMMUNITY 1501 WAS UNDER THE BANKRUPTCY COURT PROTECTION APPPELLEE MANUEL CASTRO PUT THE MARTIAL HOME IN BANKRUPTCY AND CONSPIRED TO POCKET 40,000 BY OVERVALUING THE COMMUNITY AND NOT PAYING THE HOMEMORTGAGE THE BANKRUPTCY PLAN HE SIGNED UP WHEN HE FILED BANKRUPTCY ON OR ABOUT AUG 2012.THIS EQUITY WAS ZOMBIE MONEY NOT REAL MONEY MARTIAL FRAUD IN THE AMOUNT OF 40,000 CREATE A NEW DIVORCE DECREE IN THE MARTIAL ESTATE CONCONSTITUTE TO A JUST AND RIGHT DIVISION THE COMMUNITY ESTATE DIMINSHED BY MARTIAL FRAUD OVERVALUED WITH A REALTORS OPINION.(Schlueter V.Schlueter,(Tex.l998) C ) 3rd party MISTRESS NON SPOUSE CHRISTINA PACHECO WHO IS INVOLVED IN THIS LAWSUITE HAD A REALTOR FRIEND PREPARE THE CMA-REALTORS OPINION TO BE USED IN CIVIL COURT TO HARM APPELLANT MARYANN CASTRO SHOWING REALTORS OPINION TO VALUE THE MARTIAL HOME AT 351,375 Appellee Manuel Castro aided and Sister Leila Silva and Counsel Joseph Appelt. The Comparative Market Analysis- Realtors opinion it states not to be used as an Appraisal and it was Appellant Maryann Castro has a Certified Appraisal showing the Community to be Valued at 225,000 and that is an actual value tax value is the same. D) APPELLEE MANUEL CASTRO CONSPIRED TO HARM APPELLANT MARYANN CASTRO KNOWING THE CERTIFIED APPRAISAL IS 225,000.AND THAT THERE IS NO EQUITY DUE TO NON PAYMENT OF MORTGAGE INTEREST PENALTIES ATTORNEYS FEES THAT HAVE CAUSED A LOSS IN THE EQUITY OF THE MARTIAL HOME 1501 OLIVE FRAUD WAS ATTEMPTED BY APPELLEE MANUEL CASTRO AND COUNSEL JOSEPH APPELT AND THE NON SPOUSE MISTRESS CHRISTINA PACHECO WHO CONSPIRED TO STEAL 40,000 ON PROPERTY SHE DOES NOT OWN OR HAVE INTEREST IN BY PRESENTING TO THE COURT THE OVERVALUED REALTORS OPINION OVERVALUING THE COMMUNITY AT $125,000 ON THE MARTIAL HOME APPELLEE MANUEL CASTRO SHARED WITH APPELLANT MARYANN CASTRO KNOWN AS 1501 OLIVE ST. THERE WAS NO REFINACE ALLOWED DUE TO BANKRUPTCY BY APPLEEE MANUEL CASTRO AND UNPAID MORTGAGE CAUSING A NEGETIVE STATUS OF THE ACCOUNT APPELLANT MARYANN CASTRO WAS NEVER NOTIFED OR INFORMED OF NEGETIVE STATUES ON THE HOME MORTGAGE APPELLEE MANUEL CASTRO CAUSED BY NOT PAYING THE HOMEMORTGAGE IF APPELLANT MARYANN CASTRO WOULD OF KNOWN THE TRUTH OF THE STATUS OF THE MORTGAGE APPELLEE MANUEL CASTRO HID FROM THE COURT AND APPELLANT MARYANN CASTRO ON OCT 30,2013 APPELLANT MARYANN CASTRO WOULD OF NEVER SIGNED THE AGREEMENT FOR FINAL DIVORCE ON OCT 30,2013 THIS WAS HIDDEN FROM APPELLANT MARYANN CASTRO APPELLEE MANUEL CASTRO DID THIS TO HARM APPELLANT MARYANN CASTRO CAUSING EXTREME STRESS AND ALMOST LOOSING THE MARTIAL HOME TO FORECLOURE ON JAN 6,2015. E) BANKRUPTCY PROTECTION APPELLEE MANUEL CASTRO WAS UNDER ON OCT 30,2013 SEE STATEMENT FROM THE COURT THE LIFT STAY NEVER FILED BY APPELLEE MANUEL CASTRO AND MORTGAGE PAYMENTS NOT BEING MADE BY APPELLEE MANUEL CASTRO THIS WAS HIDDEN FROM APPELLANT MARYANN CASTRO ON OCT 30,2013 APPELLANT MARYANN CASTRO PAID FOR STAY LIFT FOR APPELLEE MANUEL CASTRO UNDER THE ADVISEMENT OF COUNSEL SARAH LISHMAN APPELLEE MANUEL CASTRO SHOULD OF PAID PRIOR TO OCT 30,2013 IN ORDER TO PROCEED IN DIVORCE ON OCT 30,2013 THIS FEE WAS APPELLEE MANUEL CASTRO RESPONSIBILTY AND APPELLANT MARYANN CASTRO IS ASKING THE COURT FOR A REFUND HE FILED BANKRUPTCY NOT APPELLANT MARYANN CASTRO SHE PAID IN ORDER TO PROCEED WITH DIVORCE APPELLANT MARYANN CASTRO DID NOT BREAK ANY LAWS APPELLANT MARYANN CASTRO DID NOT APPELLANT MARYANN CASTRO IS ASKING THE COURT FOR A JUST AND RIGHT DIVORCE DECREE THAT IS CLEAN AND FAIR WITH NO FRAUD THE DIVORCE PROCESS AND THE AGREEMENT FOR FINAL DIVORCE SHE DID NOT CONSPIRE TO COMMIT FRAUD OR TRY TO STEAL EQUITY ON MORTGAGE THAT WAS OWED APPELLANT MARYANN CASTRO HAS BEEN HONEST WITH THE TRUTH AND FOR OVER A YEAR HAS BEEN TRYING TO PRESENT IT TO THE COURT THIS AGREEMENT HAS CAUSED EXTREME STRESS FINACIAL HARDSHIP ALMOST LOOSING THE MARTIAL HOME DUE TO APPELLEE MANUEL CASTRO DISHONSETY IN THE AGREEMENT FOR FINAL DIVORCE SIGNED OCT 30,2013. E) APPELLANT MARYANN CASTRO DID NOT KNOW THE HOME MORTGAGE WAS NOT BEING PAID APPELLANT MARYANN CASTRO DID NOT KNOW APPELLEE MANUEL CASTRO HAD THE MARTIAL HOME IN ACTIVE BANKRUPTCY APPELLEE MANUEL CASTRO AND THE MISTRESS WITH APPELLEE MANUEL CASTRO SISTER DIVERTED MORTGAGE MAIL TO APPELLEE MANUEL CASTRO SISTER LEILA SILVA HICKORY SHAWDOW REMOVED APPELLANT MARYANN CASTRO FROM CONTACT PERSON ON HER OWN HOME MORTGAGE SEE STATEMENT FROM WELLS FARGO APPELLANT MARYANN CASTRO EVEN RECEIVED PICTURE SHOWING HER NAME BEING REMOVED MISTRESS SENT PICTURE VIA TEXT ON CELL AND APPELLANT MARYANN CASTRQ WILL TURN OVER TO THE COURT OF APPEALS UPON REQUEST IF NEEDED F) THIS IS WHY THE AGREEMENT FOR FINAL DIVORCE SHOULD BE REPOPENED AND VOIDED MODIFIED AMENDED THERE IS FRAUD MISREPRESENTATION IN WHICH HARMED APPELLANT MARYANN CASTRO WHO HAS BEEN THE ONLY ONE HOLDING ON TO THE MARTIAL HOME 1501 OLIVE IT WAS SCHEDULED FOR FORECLOSURE JAN 6,2015 AND APPELLEE MANUEL CASTRO DID NOT AIDE IN STOPPING FORECLOSURE IT WAS APPELLANT MARYANN CASTRO WHO PREVENTED FORECLOSURE FROM BSI BANK SEE COPY OF FORECLOSURE NOTICE AND EMAIL FROM BSI ATTORNEY WITH APPELLANT MARYANN CASTRO ATTORNEY MATTHEW OBREIMER WHO IS A FORECLOSURE LAW SPECIALIST NOW THE NOTE WAS SOLD TO SN SERVICING CORPORATION AND APPELLANT MARYANN CASTRO HAS FILED FOR A LOAN MODIFICATION TO LOWER THE MORTGAGE AND PUT THE UNPAID ARREARS AT THE END OF THE NOTE DUE TO NON PAYMENT OF MORTGAGE APPELLEE MANUEL CASTRO RISKED THE COMMUNITY 1501 OLIVE TO FORECLOSURE BY NOT PAYING THE MORTGAGE AND BY BEING DISHONEST IN THE AGREEMENT FOR FINAL DIVORCE ON OCT 30,2013 . G) SUMMARY OF ARGUMENT APPELLEE MANUEL CASTRO ALLOWED FORECLOSURE ON JANUARY 6,2015 BSI FILED TO FORECLOSE IN THE AGREEMENT IT STATES THE FOLLOWING MANUEL CASTRO IS AUTHORIZED TO DO WHAT HE NEEDS TO PREVENT FORECLOSURE OF THE HOME WITHOUT HARMING MARYANN CASTRO INTEREST APPELLEE MANUEL CASTRO DID NOTHING HE COMMENTED YOU WERE PUTTING LIGHTS FOR CHRISTMAS KNOWING FORECLOSURE WAS GOING TO HAPPEN APPELLEE MANUEL CASTRO SAID THE FOLLOWING I WAS GOING TO CRY APPELLANT WAS SHOCKED TO HEAR THIS REMARK FROM APPELLEE MANUEL CASTRO WHO IS GAINFULLY EMPLOYEED MAKES 21 HOURLY AND WORKS OVERTIME APPELLEE MANUEL CASTRO DID NOT OFFER TO STOP FORECLOSURE OR TO REFUND APPELLANT MARYANN CASTRO HIS SHARE TO STOP FORECLOSURE APPELLANT MARYANN CASTRO BORROWED 3500 TO STOP FORECLOSURE SEE COPY OF CHECK AND WANTS TO BE REFUNDED APPELLEE MANUEL CASTRO DID NOTHING TO PROTECT HIS INTEREST IN THE MARTIAL HOME 1501 OLIVE ST IT WAS APPELLANT MARYANN CASTRO WHO CARRIED THE EXPENSE AND IS REQUESTING A REFUND FROM THE COURTS APPELLEE MANUEL CASTRO WAS TO HAVE PREVENTED THE FORECLOSURE AND HE DID NOTHING. APPELLANT MARYANN CASTRO HAS REPAID THE LOAN AND WANTS TO BE REIMBURSED THE 3500 SHE IS NOT EMPLOYEED SHE HAD TO SEEK EMPLOYMENT DUE TO APPELLEE MANUEL CASTRO NOT SUPPORTING HER INSTEAD APPELLEE MANUEL CASTRO USED THE COMMUNITY FUNDS TO SUPPORT HIS AFFAIR WITH MISTRESS CHRISTINA PACHECO IF APPELLANT MANUEL CAN AFFORD TO PAY FOR HIS MISTRESS THEN HE SHOULD PAY ALIMONY FOR APPELLANT MARYANN CASTRO FOR SHE WAS LEGALLY MARRIED TO APPELLEE MANUEL CASTRO FOR 29 YEARS AND IS THE DISABLED SPOUSE WITHIN THE MARRIAGE HER DISABILTY DOLLAR AMOUNT HAS DROPPED DUE TO HER TIME BEING EMPLOYEED AND THIS HARMED HER FINANCIALLY APPELLEE MANUEL CASTRO DUTY WAS TO APPELLANT MARYANN CASTRO AND HE HAS NOT FINANCIALLY SUPPORTED HER THROUGH THE PROCESS OF DIVORCE WHICH WAS TO PAY THE MORTGAGE PAYMENT AND HE DID NOT INSTEAD PAID FOR HIS EXTRA MARTIAL AFFAIR WITH THE NON SPOUSE MISTRESS CHRISTINA PACHECO. APPELLANT MARYANN CASTRO DOES NOT HAVE A CATERING BUSINESS AS COUNSEL JOSEPH APPELT HAD ATTACKED HER IN CONTESTING HER AFFIDAVIT OF INDIGENCY APPELLEE MANUEL CASTRO KNEW OF APPELLANT MARYANN CASTRO DISABILTY NOW AND DURING THE MARRIAGE HIS COMMENTS ARE YOU CAN WORK AND SHE CAN'T SHE IS UNDER DOCTOR CARE AND HER DISABILTY FUNDS HAVE BEEN LOWERED DUE TO BEING EMPLOYED APPELLANT MARYANN CASTRO WAS EMPLOYEED ONLY TO SUPPORT THE COMMUNITY 1501 OLIVE APPELLEE MANUEL CASTRO PUT IN BANKRUPTCY AND HAD NOT SUPPORTED THE DEBTS OWED IN THE MARRIAGE OF MANUEL AND MARYANN CASTRO AND SUPPORT THE COST OF LIVING NEEDS OF THE DISABLED SPOUSE APPELLANT MARYANN CASTRO APPELLEE MANUEL CASTRO HAD NOT SUPPORT APPELLANT MARYANN CASTRO DURING THE PROCESS OF DIVORCE AND ON THE FINAL DIVORCE AGREEMENT OCT 30,2013 APPELLANT MARYANN CASTRO SHOULD HAVE BEEN AWARDED ALIMONY SHE DID NOT GIVE UP HER RIGHT S COUNSEL JOSEPH APPELT TAMPERED WITH THE AGREEMENT THE ORIGINAL WAS NEVER FILED AND THERE WAS NO RECORD THAT'S WHY HE WAS PUSHING TO ENFORCE THE AGREEMENT KNOWING THE FRAUD HE CONSPIRED WITH AND TAMPERED WITH THE AGREEMENT FOR FINAL DIVORCE APPELLANT MARYANN CASTRO HAS BEEN CHALLENGING THE AGREEMENT FOR OVER A YEAR AND A HALF ANDTHE7IPW BEING PRESENTED TO APPEALS COURT THE EVIDENCE THAT SHOWS THE TRUTH AS TO WHY THE DIVORCE SHOULD BE REOPEND AND REWRITTEN TO A JUST AND RIGHT DIVORCE DECREE ALL COUNSEL JOSEPH APPPELT DID WAS PREVENT THE TRUTH FROM BEING SPOKEN IN COURT AND COST APPELLANT MARYANN CASTRO 20,000 IN ATTORNEY FEES AND APPPELLANT MARYANN CASTRO IS ASKING THE COUURT TO REFUND HER DUE TO THE DISHONESTY OF APPELLEE MANUEL CASTRO AND COUNSEL JOSEPH APPELT AND 3rd PARTY NON SPOUSE MISTRESS CHRISTINA PACHECO. THAT IS WHY APPELLANT MARYANN CASTRO HAS THIS CASE IN APPEALS COURT FOR THE TRUTH TO BE HEARD PRESENTED AND RULED WITH A JUST AND RIGHT DIVORCE DECREE NOT THE FRAUD CONSPIRACY HIDING MARTIAL ASSETS TAMPERING WITH THE AGREEMENT FOR FINAL DIVORCE THAT WAS COVERED UP ON OCT 30, 2013 COUNSEL JOSEPH APPELT ENFORCED THE AGREEMENT KNOWING APPELLANT MARYANN CASTRO WAS CHALLENGING THE AGREEMENT HE TAMPERED WITH AND JUDGE BARBRA NELLERMOC KNEW APPELLANT MARYANN CASTRO WAS IN COURT TO SPEAK ON HER RIGHT TO PROTECT HER INTEREST AND LIFE IN THE AGREEMENT FOR FINAL DIVORCE ALLOWED PREJUDICE ONLY LISTENED TO COUNSEL JOSEPH APPELT WHO IS KNOWN FOR NOT ABIDING BY THE LAW DID HE NOT RUN FOR JUDGE AND TAMPERED WITH HIS OPPENTS SIGNES WITH HIS DAUGHTER CAUGHT ON VIDEO COUNSEL JOSEPH APPELT TAMPERED WITH THE LIFE OF APPLELLANT MARYANN CASTRO BY SPEAKING TO JUDGE PRIOR TO COURT BEING DISHONEST THORUGHOUT THE WHOLE PROCESS OF DIVORCE IN THE MARRIAGE OF MANUEL AND MARYANN CASTRO AND THE AGREEMENT FOR FINAL DIVORCE ON OCT 30,2013 HOW IS THAT FAIR FOR APPELLANT MARYANN CASTRO AND COUNSEL SARAH LISHMAN SPEAKING TO JUDGES PRIOR TO COURT APPELLANT MARYANN CASTRO HEARD COUNSEL JOSEPH APPELLT TELL SARAH LISHMAN HE HAD SPOKEN TO JUDGE SAUNAS PRIOR TO COURT COUNSEL JOSEPH APPELTWAS ABUSING THE JUDICAL SYSTEM INSTEAD OF ACTING LIKE A PROFESSIONAL OFFICER OF THE COURT HE WAS CONDUCTING HIMSELF IN MISCONDUCT BY CONSPIRING IN FRAUD OVERVALUED COMMUNITY 125,000 FOR HIS CLIENT WITH REALTORS OPINION LEGAL MALPRACTICE PROCESS A DIVORCE IN ACTIVE BANKRUPTCY KNOWING HIS CLIENT HAVE NOT GOTTEN APPROVAL FROM BANKRUPTCY COURT HAD THE COMMUNITY 1501 OLIVE UNDER BANKRUPTCY CLIENT OWED AND HAD NOT MADE THE MORTGAGE PAYMENTS HIDING MARTIAL ASSETS KEOGH PLAN PENSION AND 99 SUBARU AND 95 FLEETWOOD DOUBLEWIDE HE KEPT ATTACKING APPELLANT MARYANN CASTRO IN COURT WHEN HIS CLIENT APPELLEE MANUEL CASTRO WAS COMMITING ADULTERY,FRAUD, TO HARM APPELLANT MARYANN CASTRO.AND THAT IS WHY APPELLANT MARYANN CASTRO IS CONTESTING THE AGREEMENT FOR FINAL DIVORCE AND THAT IS WHY IT SHOULD BE MODIFIED APPELLANT MARYANN CASTRO WAS HARMED. H) HIDING MARTIAL ASSETS A KEOGH PLAN PENSION 99 SUBARU AND THE 95 FLEETWOOD THE FOLLOWING INFORMATION WAS WITHHELD FROM APPELLANT MARYANN CASTRO SHE DID NOT GIVE UP HER RIGHTS TO THESE MARTIAL ASSETS. IJAPPELLEE MANUEL CASTRO COUNSEL JOSEPH APPELT SUBMITTED A MOTION TO JUDGE LITTLEJOHN THESE ASSETS WERE HIDDEN FROM APPELLANT MARYANN CASTRO AND SHE WANTS HER RIGHT TO THE KEOGH PLAN PENSION AND THE 99 SUBARU. J) THE 95 FLEETWOOD DOUBLEWIDE MOBILE HOME APPELLEE MANUEL CASTRO MISTRESS CHRISTINA PACHECO WERE COMMITING FRAUD WITH THIS ASSET THAT WAS IN THE MARRIAGE OF MANUEL CASTRO AND MARYANN CASTRO SENT TEXT TO APPELLANT MARYANN CASTRO SAYING THE MOBILE HOME WAS SOLD TO THE HERNANDEZ FOR 7000 BY GREENTREE AND THAT THERE WAS ATITTLE TRANSFER NO PAPER WORK . SEE TEXT THccf" LaJ frS? -Jc I kJU K) APPELLEE MANUEL CASTRO SURRENERED HIS INTEREST ITS LISTED AS EXEMPTED DEBT IN THE AMOUNT OF 15,445.93 LISTED IN SECTION E BANKRUPTCY OF APPELLEE MANUEL CASTRO AND THIS WAS VERIFIED BY THE DAIVIS LAW FIRM APPELLANT MARYANN CASTRO ARGUED THE DEBT WITH GREENTREE THE DEBT WAS OWED BY APPELLEE MANUEL CASTRO AND MARYANN CASTRO AND WHY DID APPELLANT MARYANN CASTRO GET A 1099 IN HER NAME DEBT WRITTEN OFF TO HER SOCIAL SECUITY NUMBER IT WAS SETTLED FOR 7000 AND IT WAS NOT SOLD TO THE HERNANDEZ IT'S A MARTIAL ASSET AND APPELLANT MARYANN CASTRO DID NOT GIVE UP HER RIGHT TO THIS ASSET AND DID NOT KNOW THE DEBT WAS SETTLED AND WRITTEN OFF IN HER NAME ONLY THIS WAS DONE WITHOUT HER CONCENT APPELLANT MARYANN CASTRO WAS TOLD THERE WAS A NOTE NOT TO BE CONTACTED WHO SET THAT UP REAMAINS UNKNOWN. LjAPPELLANT MARYANN CASTRO CALLED THE DAVIS LAW FIRM HOW CAN APPELLEE MANUEL CASTRO SURRENDER A MARTIAL ASSET WHEN IT'S A DEBT OWED BY BOTH AND PART OF THE DIVORCE AND IT DOES SAY NOT TO MAKE ANY ACCOUNT CHANGES WHILE IN PROCESS OF DIVORCE APPELLANT MARYANN CASTRO WAS TOLD HE CAN7HOW? THE COURT WAS NOT NOTIFIED NOR WAS APPELLANT MARYANN CASTRO LAWS BROKEN TO HARM APPELLANT MARYANN CASTRO ?HOW IS THAT JUSTICE? APPELLEE MANUEL CASTRO AND THE NON SPOUSE MISTRESS WERE CHANGING ACCOUNT MATTERS PUTTING THE DEBT ACCURED IN THE MARRIAGE OF MANUEL AND MARYANN CASTRO ON APPELLANT MARYANN CASTRO THE DEBT OF THE MOBILE HOME WAS SETTLED WITH GREENTREE FOR 7000 AND WRITTEN OFF IN APPELLANT MARYANN CASTRO NAME SOCIAL SECURITY THE 1099 SHE RECIVED FOR 2014 THE NOTE WAS NOT SOLD TO THE HERNANDEZ ONLY AS RENT TO OWN WITH TERMS AND THEY HAVE NOT PAID OR FOLLOWED AGREEMENT SEE COPY APPELLANT MARYANN CASTRO HAS SENT THE HERNANDEZ PARTY IN SOMMERSET TEXAS A NOTICE TO PAY THERE ARE TWO TAX LEINS 2013,2014 FILED AGAINST THE 95 FLEETWOOD IN ATASCOSA COUNTY AND THERE IS NO TITTLE TRANSFER THE 95 FLEETWOOD IS OWED TO APPELLANT MARYANN CASTRO AND SHE HAS SUBMITTED TO THE COURT IN BEXAR COUNTY THE PROOF AND HAS SUBMITTED TO THE HERNANDEZ 30 DAY NOTICE TO PAY OR REPOSSESSION WILL TAKE PLACE APPELLANT MARYANN CASTRO IS NEEDING THE HELP OF THE COURT TO GRANT APPELLANT MARYANN CASTRO THE PERMISSION AND IS NEEDING ALIMONY TO PAY THE UNPAID TAXES SEE COPY SHE CANNOT PAY THE DEBTS OWED BY APPELLEE MANUEL CASTRO APPELLANT MARYANN CASTRO IS DISABLED AND ON A FIX INCOME SEE SOCIAL SECURITY STATEMENT M) THERE ARE TAXES THAT NEED TO BE PAID APPELLEE MANUEL CASTRO OWES TO THE MOBILE HOME AND TO THE COMMUNITY AT 1501 OLIVE SHE HAS TRIED TO COMMUNITCATE WITH APPELLEE MANUEL CASTRO ABOUT THESE MATTERS AND HE REFUSES TO SUPPORT KNOWING THE COUNTY OF ATASCOSA CAN LEGALLY ENFORCE AND NOTICES HAVE BEEN SENT TO ENFORCE ON THE COMMUNITY APPELLANT MARYANN CASTRO HAS BEEN PAYING MONTHLY THE TAXES THAT ARE OWED BY BOTH APPELLEE MANUEL CASTRO NEEDS THE ALIMONY SUPPORT OF APPELLEE MANUEL CASTRO ~1~Q APPELLANT MARYANN CASTRO IS DISABLED AND NOT EMPLOYED APPELLANT MARYANN CASTRO CURRENTLY UNDER DOCTORS CARE. M) FRAUD ON THE COMMUNITY AND MARTIAL ASSET A FIDUCIARY DUTY EXISTS BETWEEN THE SPOUSES REGARDING THE COMMUNITY PROPERTY AND APPELLEE MANUEL CASTRO DID CONSPIRE TO COMMIT FRAUD WITH THE AIDE OF HIS MISTRESS NON SPOUSE CHRISTINA PACHECO BY PRESENTING TO THE COURT A FALSIFIED COMPARTIVE MARKET ANALYSIS REALTORS OPINION AND IT SAYS NOT TO BE USED AS AN APPRAISAL IT'S A REALTORS OPINION AND IT WAS USED TO TRY TO FALSELY GAIN FRAUD EQUITY IN THE AMOUNT OF 125,000 TO POCKET 40,000 WHEN THE HOME CERTIFIED VALUE IS 225,000 NOT THE REALTORS OPINION PRESENTED ON OCT 30,2013 THE REALTORS OPINION IS 351,375 THERE ARE ONLY 3 HOMES IN THE AREA AND APPELLEE MANUEL CASTRO KNEW THIS AND KNEW THE REALTORS OPINION SET UP BY HIS MISTRESS CHRISTINA PACHECO WAS INCORRECT APPELLEE MANUEL CASTRO DID THIS TO HARM APPELLANT MARYANN CASTRO AND IT DID MISREPRESENTINGTTHETOMMWITY VALUE U3iN1TA REALTbRSOPINI^N INSTEAD OF APPELLANT MARYANN CASTRO CERTIFIED APPRAISAL 225,000 A FIDUCIARY DUTY EXISTS BETWEEN THE SPOUSES AND APPELLEE MANUEL CASTRO WAS ALLOWING THE MISTRESS TO HARM APPELLANT MARYANN CASTRO WITH THE REALTORS OPINION BY BEING DISHONEST IN OVERVALUING THE COMMUNITY 1501 OLIVE ST 125,000 THE MARTIAL PROPERTY THAT WAS SHARED BETWEEN APPELLEE MANUEL CASTRO AND APPELLANT MARYANN CASTRO.( IN THE MARRIAGE OF MOORE 890.SW 2D 821,827,TEX-APP-AMARILLO 1994 NO WRITJIT IS CONSTRUCTIVELY FRAUD WHEN ONE SPOUSE DISPOSE OF THE OTHER SPOUSE INTEREST IN THE COMMUNITY WITHOUT THE CONCENT OF THE OTHER SPOUSE APPELLEE MANUEL CASTRO MISTRESS SENT TEXT TO APPELLANT MARYANN CASTRO SAYING N)THE FOLLOWING TEXT WAS SENTTO APPELLANT MARYANN CASTRO BY 3rd PARTY NON SPOUSE CHRISTINA PACHECO GREENTREE SOLD HERNANDEZ MOBILE HOME FOR 7000 AND TITLE TRANSFER NO PAPERWORK THIS WAS A LIE APPELLANT MARYANN CASTRO JUST DISCOVERED THE TRUTH 6/2015 THE 3RP PARTY NONSPOUSE MISTRESS CHRISTINA PACHECO KEPT SENDING TEXT MESSAGES TO APPELLANT MARYANN CASTRO PRETENDING TO BE APPELLEE MANUEL CASTRO SELL THE HOME THAT WAS SHARED BY APPELLEE MANUEL CASTRO AND APPELLANT MARYANN CASTRO 3rd PARTY NONSPOUSE MISTRESS CHRISTINA PACHECO CONSPIRED TO DISPOSE A MARTIAL ASSET THAT DID NOT BELONG TO HER VALUED AT ALMOST 20,000 SEE TAX VALUE AND WAS TRYING TO SELL APPELLANT MARYANN CASTRO MARTIAL HOME BY USING HER AFFAIR WITH APPELLEE MANUEL CASTRO AND COMMUNICATING WITH COUNSEL JOSEPH APPELT WHO FILED A MOTION TO ENFORCE SELL BY ENFORCING A REALTOR WHO SET UP THE FRAUD IN OVERVALUING THE COMMUNITY AT OVER 125,000 IT WAS DENIED WITH DISRESPECT TO APPELLANT MARYANN CASTRO SHE WAS DISPOSING ATTEMPTING TO DISPOSE AN ASSET THAT HAS VALUE AND THE MARTIAL HOME 1501 OLIVE APPELLANT MARYANN CASTRO SHARED WITH APPELLEE MANUEL CASTRO THE 3rd PARTY MISTRESS WAS CONSPIRING TO STEAL,40,000 WITH APPELLEE MANUEL CASTRO AIDING 0)ATASCOSA COUNTY HAS A TAX LEIN 2013,2014 TOTAL DUE 734.71 ON THE 95 FLEETWOOD DOUBLEWIDE SEE COPY .APPELLANT MARYANN CASTRO HAS MADE CONTACT WITH THE URBAN HOUSING AND DEVELOPMENT TO ASSURE THE TITTLE HAD NOT BEEN TAMPERED WITH AND IT HAS NOT IT WILL NOT BE RELEASED TO ANYONE OTHER THAT APPELLANT MARYANN CASTRO AND THE TITTLE WILL NOT BE RELEASED UNTIL THE TAXES ARE PAID 2013,2014 AND THEREFORE HAVE TWO LEINS AS OF 6/14/2015 APPELLEE MANUEL CASTRO HAS BEEN NOTIFIED APPELLANT MARYANN CASTRO NEEDS TO ALIMONY TO MAINTAIN HER COST OF LIVING IT WAS APPELLEE MANUEL CASTRO WHO COMMITED ADULTERY, AND FRAUD AND HAS NOT SUPPORTED APPELLANT MARYANN CASTRO OR THE DEBT THAT OCCURRED IN THE MARRIAGE OF MANUEL AND MARYANN CASTRO APPELLANT MARYANN CASTRO IS DISABLED AND CANNOT SUPPORT THE MARTIAL DEBTS OCCURRED IN THE MARRIAGE OF MANUEL AND MARYANN CASTRO BY HERSELF APPELLEE MANUEL CASTRO MAKES MORE MONEY THAN APPELLANT MARYANN CASTRO APPELLEE MANUEL CASTRO DID CAUSE THE MARTIAL DEBTS TOO AND SHOULD BE HELD LIABLE LIKE THE UNPAID MORTGAGE HE FAILED TO PAY THAT WAS TO BE PAID TO SUPPORT APPELLANT MARYANN CASTRO INSTEAD HE USED THE COMMUNITY FUNDS TO SUPPORT HIS EXTRA MARTIAL AFFAIRWITH 3rd PARTY MISTRESS NON SPOUSE CHRISTINA PACHECO SEE TEXT SENT TO APPELLANT MARYANN CASTRO BY THE 3rd PARTY NON SPOUSE MISTRESS CHRISTINA PACHECO NOWORK NO MONEY NO HOUSE PAYMENT COURT OR NOT SORRY NOW IS THAT NOT DISRESPECTING THE COURT AND THE SPOUSE OF APPELLEE MANUEL CASTRO THE PAYMENTS WERE COURT ORDER AND APPELLEE MANUEL CASTRO WAS AIDING THE 3rd PARTY MISTRESS CHRISTINA PACHECO IN FRAUD,DISPOSING A MARTIAL ASSET,HIDING MARTIAL ASSETS, AND HARRASSING APPELLANT MARYANN CASTRO ONLY TO HARM HER. APPELLANT MARYANN CASTRO IS ASKING THE COURT TO REFUND HER FOR THE UNPAID MORTGAGE THAT APPELLEE MANUEL CASTRO DID NOT PAY THAT WAS SUPPORT FOR APPELLANT MARYANN CASTRO SEE BSI STATEMENT APPELLEE MANUEL CASTRO MISTRESS CHRISTINA PACHECO ATTEMPTED TO DISPOSE THIS MARTIAL ASSET THAT HAS INTEREST TO APPELLANT MARYANN CASTRO AND IS A MARTIAL ASSET THIS WAS DONE TO HARM APPELLANT MARYANN CASTRO. PJJOHNSON CONTROL RETIREMENT AND ALIMONY.APPELLANT MARYANN CASTRO DID NOT GIVE UP HER RIGHT TO ALIMONY AND THE MARTIAL ASSET JOHNSON CONTROL RETIREMENT IN THE AMOUNT OF 11,000 AND IS REQUSTING THE APPEALS COURT FOR 10,000 FOR THE MORTGAGE ALIMONY FOR SUPPORT IN THE AMOUNT OF 1500 MONTHLY TO BE PAYROLL DEDUCTED WEEKLY IN THE AMOUNT OF 375 APPELLANT MARYANN CASTRO IS DISABLED AND WAS THE v yeiwis ) SPOUSE OF APPELLEE MANUEL CASTRO FOR 29 COUNSEL JOSEPH APPELT TAMPERED WITH THE AGREEMENT TO CAUSE HARM TO APPELLANT MARYANN CASTRO THE AGREEMENT FOR FINAL DIVORCE SIGNED OCT 30,2013 AND THAT IS WHY THE AGREEMENT FOR FINAL DIVORCE NEEDS TO BE REOPENED AND MODIFIED APPELLEE MANUEL CASTRO AND COUSEL JOSEPH APPELTAND 3rd PARTY NON SPOUSE MISTRESS CHRISTINA PACHECO DID HARM APPELLANT MARYANN CASTRO WITH FRAUD. rX Pf&feS . 99 SUBARU APPELLANT MARYANN CASTRO DID NOT GIVE UP HER RIGHT TO THIS MARTIAL ££>£> 9703, ASSET ITS NOT EVEN IN THE AGREEMENT FOR FINAL DIVORCE IT WAS HIDDEN FROM HER AND IS ASKING THE COURT TO RETURN THE 99 SUBARUTO APPELLANT MARYANN CASTRO APPELLEE MANUEL CASTRO WAS GIVEN A 99 FORD COUNTOUR AND STATES THE FOLLOWING IT WAS STOLEN OR BROKEN IN MEDIATION SHE WAS TOLD THIS AND NO POLICE REPORT FILED CAUSING A LOSS IN A MARTIAL ASSET AND DID NOT NOTIFY THE POLICE BUT THE MISTRESS WAS SENDING TEXT TO APPELLANT MARYANN CASTRO FOR TITTLE APPELLANT MARYANN CASTRO NEVER HANDED THE MISTRESS THE TITTLE WHO WAS PRETENIDING TO BE APPELLEE MANUEL CASTRO THE 99 COUNTOUR WAS SOLD TO PAY FOR THE MISTRESS DIVORCE APPELLLEE MANUEL CASTRO AIDED HER IN STEALING FROM APPELLANT MARYANN CASTRO. KEOGH PLAN PENSION APPELLANT MARYANN CASTRO DID NOT GIVE UP HER RIGHT TO THIS ASSET THAT WAS HIDDEN FROM HER ITS NOT EVEN IN THE AGREEMENT FOR FINAL DIVORCE APPELLANT MARYANN CASTRO WANTS HER SHARE SHE IS ENTITLED TO. Q) DEBTS THAT OCCURRED WITHIN THE MARRIAGE OF MANUEL AND MARYANN CASTRO APPELLANT MARYANN CASTRO PRAYS FOR THE COURT TO GRANT HER 1500 ALIMONY THE SUPPORT THAT IS NEEDED TO MAINTAIN A COST OF LIVING APPELLANT IS DISABLED AND BECAME DISABLED WITHIN THE MARRIAGE OF MANUEL AND MARYANN CASTRO 29 YEARS AND PREJUDICE WAS BROUGHT UPON HER DISABILITY RIGHTS AS A DISABLED SPOUSE IN A MARRIAGE THAT EXCEEDED IN OVER 10 YEARS AND ENDED DUE TO APPELLEE MANUEL CASTRO CARRYING AN EXTRA MARTIAL AFFAIRWITH 3rd PARTY NON SPOUSE MISTRESS CHRISTINA PACHECO LISTED IN THIS LAWSUITE IN THE AGREEMENT FOR FINAL DIVORCE APPELLANT MARYANN CASTRO SOCIAL SECURITY HAS DROPPED TO DUE THE NONSUPPORT OF APPELLEE MANUEL CASTRO WHERE SHE HAS BEEN THE ONLY ONE SUPPORTING THE MARTIAL HOME PREVENTING FORECLOSURE FROM THE BANK AND THE ATACOSA TAX OFFICE BY FUNDING THE EXPENSE THAT APPELLEE MANUEL CASTRO IGNORES AND REFUSES TO PAY AND SUPPORT A DEBT THAT WAS CAUSED BY HIS DISHONESTY IN THE AGREEMENT FOR FINAL DIVORCE SIGNED OCT 30, 2013. BREACH OF FIDUCIARY DUTY BY FRAUD SEPT 1, 2011 THE TEXAS LEGISLATURE ADDED7.009 TO THE TEXAS FAMILY CODE WHICH MANDATES COURTS TO RECONSTITUTE THE COMMUNITY ESTATE UPON FINDING FRAUD. IN ADDITION, ACTS BY EITHER SPOUSE RESULTING IN EXCESSIVE OR ABNORMAL EXPENDITURES,DESTRUCTION, CONCEALMENT,OR FRAUDULENT DISPOSITION OF COMMUNITY PROPERTY, JO|NT TENANCY, OR OTHER PROPERTY HELD IN COMMON IS A FACTOR FOR A COURT TO CONSIDER IN AWARDING SPOUSAL MAINTENCE. WHAT CONSTITUTES FRAUD A. SPRICK V. SPRICK ,25 S.W. 3D 7(TEX.APP-EL PASO 1999,PET.DENIED)COMMUNITY FUNDS EXPENDED ON PARAMOURS MATERIAL THAT WAS MISREPRESENTED ACTUAL FRAUD STONEV. LAWYERS TITLE INSURANCE CORP., 554 S.W.2D 183,185(TEX 1977) A BREACH OF FIDUCIARY DUTY IS FREQUENTLY TERMED AS FRAUD ON THE COMMUNITY IN RE MARRIAGE OF MOORE, 890 S.E.2D 821,827(TEX.APP-AMARILLO 1994,NO WRIT) CONSTRUCTIVE FRAUD INCLUDES ACTIONS OF ONE SPOUSE UNFAIRLY DISPOSING OF OR ENCUMBERING THE OTHER SPOUSE INTEREST IN COMMUNITY PROPERTY OR UNFAIRLY INCURRING COMMUNITY INDEBTNESS WITHOUT THE OTHER SPOUSES KNOWLEDGE OR CONCENT. MASSEY V.MASSEY,807 S.W. 2D391,402(TEX.APP-HOUSTON[1ST DISTRICT]1991)WRIT DENIED,867 S.W. 2D 766(TEX.1993)CONFIDENCES THAT EXIST AS A RESULT OF THE MARRIAGE.ID.AT 827. THE FOLLOWING DEBTS OCCURRED IN THE MARRIAGE OF MANUEL AND MARYANN CASTRO MORTGAGE UNPAID ARREARS SEE BSI STATEMENT- SEE STATEMENT APPELLEE MANUEL CASTRO OWES THE DEBT AND CAUSED THE DEBT TO EXCEED DUE TO HIS DISHONESTY. TAXES 95 FLEETWOOD 2013,378.81 2014 355.90 SEE STATEMENT "1501OLIVE MARTIALHOME BALANCE FOR 2013-$725 SEE STATEMENT APPELLANT MARYANN- CASTRO PAID 900 DID NOT KNOW TAXES WERE NOT BEING PAID AND DID NOTIFY APPELLEE MANUEL CASTRO. ATTORNEY FEES COST 20,000 IN 3 YEARS APPELLANT MARYANN CASTRO HAS PAID FOR APPELLEE MANUEL CASTRO DISHONESTY AND EXTRA MARTIAL AFFAIR PRAYS FOR THE COURT TO REFUND HER FOR IT WAS MANUEL CASTRO WHO COMMITED FRAUD AND ADULTERY WITH THE 3rd PARTY NON SPOUSE MISTRESS CHRISTINA PACHECO APPELLANT MARYANN IS NOT EMPLOYED AND HAS DISABILTY INCOME IN THE AMOUNT OF 854 MONTHLY AND PRAYS THE COURT TO GRANT HER ALIMONY SPOUSAL MAINTENCE IN THE AMOUNT OF 1500 MONTHLY. STUDENT LOAN DEBT IN THE AMOUNT OF 35,000 THIS WAS USED WITHIN THE MARRIAGE OF MANUEL AND MARYANN CASTRO AND IS INDEFFERMENT SEE COPY TOTAL DEBT AS OF JUNE 16,2015 TOTALS TO THE AMOUNT OF 116,459.71 APPELLANT MARYANN CASTRO NEEDS THE SUPPORT OF APPELLEE MANUEL CASTRO APPELLEE MANUEL CASTRO HAS CAUSED THIS DEBT AND HAS NOT SUPPORTED THE COMMUNITY IN THE MARRIAGE OF MANUEL AND MARYANN CASTRO THAT ENDED WHEN HE BEGAN HIS EXTRA MARTIAL AFFAIR ON OR ABOUT JULY 3,2011 AND HAS BEEN USING THE COMMUNITY FUNDS TO FUND HIS EXTRA MARTIAL AFFAIR WITH 3rd PARTY NON SPOUSE MISTRESS CHRISTINA PACHECO.APPELLANT MARYANN CASTRO PRAYS FOR THE COURT TO GRANT HER SUPPORT ALIMONY IN THE AMOUNT OF 1500 MONTHLY TO BE PAYROLL DEDUCTED WEEKLY APPELLEE MANUEL CASTRO HAD A FIDUCIARY DUTY TO APPELLANT MARYANN CASTRO AND APPELLEE MANUEL CASTRO COMMITED CONSTRUCTIVE FRAUD TO DECEIVE APPELLANT MARYANN CASTRO AND VIOLATED THE CONFIDENCE TO INJURE APPELLANT MARYANN CASTRO. RELIEF FROM AGREEMENT THE PURPOSE WAS TO DEFRAUD APPELLANT MARYANN CASTRO OUT OF THE FOLLOWING HER HOMESTEAD THE MARTIAL HOME SHE HAS RESIDED AT SINCE 1995 APPELLEE MANUEL CASTRO AND COUNSEL JOSEPH APPELT KNEW THE COMMUNITY WAS IN JEPORDY OF FORCLOSURE AND HAD THE MARTIAL HOME IN ACTIVE BANKRUPTCY ON OCT 30,2013.CHANGE OF ADDRESS REMOVE APPELLANT MARYANN CASTRO NAME FROM CONTACT PERSON WELLS FARGO NOTIFIED APPELLANT MARYANN CASTRO THAT CHRISTINA PACHECO HAD TOLD THEM THE FOLLOWING REMOVE APPELLANT MARYANN CASTRO NAME APPELLEE MANUEL CASTRO DIVORCE HER AND THIS WAS WHEN APPELLANT MARYANN CASTRO HAD BEEN IN CONTACT WITH BANK CHECKING STATUS OF A LOAN MODIFICATION TO LOWER MORTGAGE PAYMENT IT WAS 1789.45 AND WHEN APPELLANT MARYANN CASTRO WAS NOTIFIED SHE WAS TOLD THAT THE REPRESENATIVE DESIREE DID TELL CHRISTINA PACHECO APPELLANT MARYANN CASTRO NEEDS TO SEND IN A LETTER OF REQUEST DESIREE WAS THE CONTACT PERSON THIS WAS DONE ABOUT 8/2012~AND THE NONSPOUSE-" MISTRESS CHRISTINA PACHECO SENT PICTURE TO APPELLANT MARYANN CASTRO VIA PICTURE SHOWING HER NAME REMOVED AND SENT NOTICE TO WELLSFARGO FORGING APPELLANT MARYANN CASTRO NAME AND APPELLEE MANUEL CASTRO NAME AND MAIL FOWARDED TO APPELLEE MANUEL CASTRO SISTER LEILA SILVA OF ELMINDORF WHO ALSO WAS INVOLVED IN HARMING APPELLANT MARYANN CASTRO OF HER INTEREST IN THE MARTIAL HOME 1502 OLIVE. THE NON SPOUSE MISTRESS ALSO SENT TEXT TO APPELLANT MARYANN CASTRO QUESTIONING HER ABOUT DOCUMENT IS NEEDED FOR MODIFICATION BY BSI SEE TEXT ALSO CALLING HER NASTY NAMES THE MISTRESS CHRISTINA PACHECO CONSPIRED TO COMMIT FRAUD OF PROPERTY THAT IS IN THE MARRIAGE OF MANUEL AND MARYANN CASTRO TO CAUSE HARM TO APPELLANT MARYANN CASTRO WITH THE AIDE OF APPELLEE MANUEL CASTRO WHO ALLOWED THIS TO INTENTIONALLY HARM APPELLANT MARYANN CASTRO WITH FRAUD. APPELLEE MANUEL CASTRO MISTRESS CHRISTINA PACHECO HAS NO INTEREST IN ANY OF THE ASSETS, MARTIAL HOME 1501 OLIVE, 95 FLEETWOOD MOBILE JOHNSON CONTROL AND KEOGH RETIREMENT AND 99 SUBARU THAT WAS IN THE MARRIAGE OF MANUEL AND MARYANN CASTRO THE MISTRESS HAS CONSPIRED IN FRAUD, THEFT, FORGERY, MAILFRAUD AND APPELLEE MANUEL CASTRO AIDED IN CRUELTY TO HARM APPELLANT MARYANN CASTRO DUE TO HIS EXTRA MARTIAL AFFAIR WITH CHRISITNA PACHECO FOR IT WAS APPELLEE MANUEL CASTRO WHO COMMITED ADULTERY. APPELLEE MANUEL CASTRO PUT THE COMMUNITY IN BANKRUPTCY WITH THE RISK OF FORECLOSURE KNOWING HE WAS NOT MAKING THE MORTGAGE PAYMENTS AND JEPORADIZING THE INTERST OF APPELLANT MARYANN CASTRO TO HARM HER ON JAN 6,2015 APPELLANT MARYANN CASTRO STOPPED FORECLOSURE FROM BSI APPELLEE MANUEL CASTRO DID NOTHING HE WAS GOING TO ALLOW FORECLOSURE KNOWING APPELLANT MARYANN CASTRO INTERST WOULD BE JEPORADIZE AND WOULD BE HOMELESS BSI BANK LOWERED MORTGAGE TO 1600 BUT WANTED ARREARS ABOUT 45,000 SEE EMAIL FROM ATTORNEY MATTHEW OBREMIER WHO HAS BEEN RETAINED TO PROTECT APPELLANT MARYANN CASTRO INTERST IN THE MARTIAL HOME THAT SHE SHARED WITH APPELLEE MANUEL CASTRO BSI BANK SOLD NOTE TO SN SERVICING AND APPELLANT MARYANN CASTRO HAS SUBMITTED A LOAN MODIFICATION APPLICATION TO LOWER THE MORTGAGE AS OF NOW ITS 1600 APPELLANT MARYANN CASTRO IS NEEDING ALIMONY SUPPORT BY APPELLEE MANUEL CASTRO THAT SHOULD HAVE BEEN ENTERED OCT 30, 2013 APPELLANT MARYANN CASTRO INTEREST IS STILL AT RISK DUE TO NON PAYMENT OF MORTGAGE PRIOR TO APPELLANT, MARYANN CASTRO BEING AWARDED THE MARTIAL HOME 1501 OLIVE APPELLEE MANUEL CASTRO HAD THE HOME IN ACTIVE BANKRUPTCY AND WAS NOT PAYING THE MORTGAGE APPELLEE MANUEL CASTRO WAS PUTTING THE UNPAID DEBT HE WAS TO HAVE PAID ON APPELLANT MARYANN CASTRO BY HIDING FROM THE COURT THE BANKRUPTCY ACTIVE AND NON PAYMENT OF MORTGAGE AND THIS WAS DONE TO HARM APPELLANT MARYANN CASTRO "APPELLEE MANUELCASTROOVERVALUEDTHE COMMUNITY USINGA REALTORS OPlNrONTO HARM APPELLANT MARYANN CASTRO AND IT DID ALMOST LOOSING THE MARTIAL HOME TO FORECLOSURE ON 1/6/2015 APPELLLANT MARYANN CASTRO HAS DISCUSSED WITH APPELLEE MANUEL CASTRO THE MATTERS OF THE MORTGAGE, TAXES, INSURANCE NEEDING SUPPORT AND HE REFUSES SAYS HE HAS NO MONEY HE IS A WELDER AND MAKES 21 HOURLY WORKS OVERTIME AND OWES A HIGH DOLLAR AMOUNT ON THE MORTGAGE HE DID NOT PAY IT IS A DEBT HE CAUSED BY BEING DISHONEST AND CARRYING AN EXTRA MARTIAL AFFAIR WHEN APPELLEE KNEW IT WAS COURT ORDER TO PAY. APPELLLEE MANUEL CASTRO HAS BEEN USING THE COMMUNITY FUNDS TO FUND HIS AFFAIR WITH MISTRESS CHRISTINA PACHECO WHO IS EMPLOYED AND HAS A HOME HE HAS BEEN LIVING WITH HER DURING THE MARRIAGE OF MANUEL AND MARYANN CASTRO WHICH ENDED DUE JULY 2011 APPELLEE MANUEL CASTRO COMMITED ADULTERY WITH NON SPOUSE MISTRESS CHRISTINA PACHECO WHO IS PART OF THIS LAWSUITE AND NOT ENTITLED TO ANY MONETARY FUNDS RETIREMENT KEOGH PENSION PLAN JOHNSON CONTROL RETIREMENT ASSETS 95 FLEETWOOD MOBILE HOME,99 SUBARU,1501 OLIVE ST THE MARTIAL HOME WHERE APPELLANT MARYANN CASTRO LIVES AND WAS AWARDED UNDER MISREPRESENTATION THAT HOME WAS BEING PAID AND APPELLEE MANUEL CASTRO HAD THE MARTIAL HOME IN ACTIVE BANKRUPTCY ON THE DAY THE AGREEMENT FOR FINAL DIVORCE WAS SIGNED OCT 30,2013. THE PRAYER APPELLANT REQUEST REOPEN THE DIVORCE AGREEMENT AMEND MODIFY REWRITE THE AGREEMENT FOR FINAL DIVORCE TO A JUST AND RIGHT DIVORCE DECREE APPELLANT MARYANN CASTRO WAS HARMED AND THE APPELLANT BRIEF HAS STATES HER REQUEST AND TO INCLUDE 95 FLEETWOOD DOUBLEWIDE A MARTIAL ASSET THAT WAS HIDDEN FROM HER DISCOVERED 6/2015 APPELLANT MARYANN CASTRO PRAYS FOR RELIEF SHE WILL ACCEPT THE AWARD OF THE MARTIAL HOME BUT NEEDS THE SUPPORT OF ALIMONY FOR COST OF LIVING IN THE AMOUNT OF 1500 MONTLY IT WAS APPELLANT MARYANN CASTRCM&JHE ONLY WHO HAS PREVENTED FORECLOSURE AND PROTECTED HER INTERST IN THE RESIDENCE 1501 OLIVE WHILE APPELLEE MANUEL CASTRO WAS MANUEL WAS CARRYING ON HIS HIS EXTRA MARTIAL AFFAIR WITH 3rd PARTY NON SPOUSE MISTRESS CHRISTINA PACHECO. APPELLANT MARYANN CASTRO PRAYS FOR JUSTICE AND THE RELIEF SHE IS ENTITLED TO. RESPECTFULLY MARYANN CASTRO PRO-SE APPELLANT 1501 OLIVE JOURDANTON TEXAS 78026 PACATTITUDE 2014@GMAIL.COM 830-496-0133 SENT 6/16/2015 AND DELIVERED TO APPELLEE MANUEL CASTRO AT 624 W. GOODWIN PLEASANTON TEXAS 78026 BY NATALIE LUGO - •-I. «,„u™ M CATJSENO. QD" -CXr &fo^- ityt^ fMHtMSfML MTHEDISTJRICT COURT ^rf i^JUDICIALDISTRICT VWf hMl&ttto BEXAHCOUNTY,TEXAS {flL 0aiweflt) ac£reement for Pt'/vaJ Divfov^e^ Onthe O® day of QCaw6|£. .20 13 , came on to be heard the above styled and numbered cause of action. Perftjonerand Respondentappeared in personand annotmcedready. Afisr conference, the parties reached an agreement onthe terms and conditionsset forth below. By the signatures below the parries acknowledge that t M^>y.\"£ .#-• itire understanding and accord oftae parties ia consentthat the Coxaf;'^^f> •: ^±^<\ -.Av'-f^^v, safer binding orders in accordance with this agreement ben-no lft£fr/4to^ feiffUfru ^8^14 U-gip/vi - ffi/^gaffiyY^PHtfa/fymhiS ^esftyEJtorta- (^AMfft^r^^j(?UAf4fcAed ^mart-far O1^*82 tAt>tQDD £fo4M ^a^ ~k Mstod^flmo^dl Wtefrfein tome (Whey" 5. Oebfe t fetch Qojfox is y^-p^fe-fi/-fre. jfcHs.Vi>toiy mme^ Pags 1of2 Parties/Attorneys foaiaJs ftfy? /V\ f^C-*-' CAUSE NO. jZ6[\ -f>X- 15°[ 5^- page. All pa'feS nafia Wynj f„ ,11 [ , : • ——__ SK^mdENrafiH)Ml4is_3D_da7of_J2^fcg^ -20J3 APPROVED ASTOFORM; ^^p^^^Sa^SEs AS^S^^^^^ APPROVED AS T03POKMAND SDBSTANCF. &_ ^"Ao> Ga^Ds Ac oty&Y&r M^Mm^r fwdvfflft HV^&m^sK © nff Mfce* Olive. Stvtet: Iwe is flmJbb fe> fag, vfc&Yiani-ed 'solA oral ^4otDOP sfoul foe* dU/a&tet 4-puCslb ^/^£idts>'f>rt> aY^%&h^^Bt%esWX£eAS> ^^' ^pi&^awrfcte? i> MWjfWl Cftgfrp J bA OBftteaterf^ fssoe/^ IQsp, ciete^Mviegl -Kmo -W fE^nqj^Urvp^ \-to ftto*j ^spH it E JM.C \ \ f*\ f f*- 'T •!•': J ,'"- IN THE MATTER OF H OCT !2 AH 9-S&0 IN THE DISTRICT COURT THE MARRIAGE OF § MANUEL G. CASTRO § 45TH JUDICIAL DISTRICT AND 'BY_ S MARY ANN CASTRO § BEXAR COUNTY, TEXAS ORIGINAL COUNTERPETITION FOR DIVORCE 1. Discovery Level Discovery in this case is intended to be conducted under level 2 of rule 190 of the Texas Rules of Civil Procedure. 2. Parties This suit is brought by MARY ANN CASTRO, Counterpetitioner. The last- three numbers of MARY-ANN CASTRO's driver's license number are "7^ - The; last three numbers of MARY ANN CASTRO's Social Security number are fff 5 . ; MANUEL G. CASTRO is Counterrespondent. 3. Domicile • ' , Counterpetitioner has been a domiciliary of Texas for the preceding six-r^pnth periqd and a resident of this 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, JR., 5825 Callaghan Rd, 104, San Antonio, Texas 78228 in open court. 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 of Marriage 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. Grounds for Divorce The marriage has become insupportable because of discord or conflict of personalities between Counterpetitioner and Counterrespondent that destroys the legitimate ends of the marriage relationship and prevents any reasonable expectation^ of reconciliation, Counterrespondent is guilty- of cruel treatment toward Counterpetitioner of a nature that renders further living together insupportable., - Counterrespondeint has committed adultery. 8. Child of the Marriage There is no child born or adopted of this marriage, and none is ,expected. '"••>• 'A\ .-••' 9. \; Marital-Prpperty Agreement • Counterpetitioner .and Counterrespondent will likely enter into a marital-property agreement defining their rights to all their property, both community and separate. Counterpetitioner requests the Court to enforce the agreement and divide the marital estate in accordance with its terms. 10. Separate-Property Confirmation Counterpetitioner owns certain separate property that is not part of the community estate of the parties, and Counterpetitioner requests the Court to confirm such separate property as Counterpetitioner's separate property and estate. 11. Reimbursement Counterpetitioner .requests the Court to reimburse Counterpetitioner \s separate estate for funds or assets expended by Counterpetitioner's separate estate for the benefit of the community. Those expenditures resulted in a direct benefit to the community estafe. Counterpetitioner' s separate estate has not been adequately compensated for or benefited from the expenditure of thqse; funds or assets, and a failure by the Court to allow reimbursement to Counterpetitioner's separate estate will result in an unjust enrichment of the community estate at. the expense of Counterpetitioner's separate estate. :. 12. Postdivorce Maintenance The Cqunterpetitiqner also requests the Court to order that she be paid postdivorce maintenance for a reasonable period in accordance with chapter 8 of the Texas Family Code. 13. Request for Temporary Orders Counterpetitioner requests the Court to dispense with the issuance of a bond and after notice and hearing be temporarily enjoined, pending the further order of this Court, from: 1. Communicating with Counterpetitioner in person, by telephone, or in writing in vulgar, profane, obscene, or indecent language or in a coarse or offensive manner. 2. Threatening Counterpetitioner in person, by telephone, or in writing to take unlawful action against any person. 3. Placing one or more telephone calls, anonymously, at any unreasonable hour, in an offensive and repetitious manner, or without a legitimate purpose of communication. 4. Causing bodily injury to Counterpetitioner. 5. Threatening Coupterpetitipner with imminent bodily injury, <5. Destroying, removing, - concealing, encumbering, transferring, or otherwise harming or reducing the value of the property of one or both of the parties, 7.. Falsifying any writing pr record relating to the property of either party. : 8. Misrepresenting or refusing to disclose to Counterpetitioner or to the Court, on proper request, the existence, amount, or location of any property of one or both of the parties. 9. Damaging or destroying the tangible property of one or both of the parties, including any document that represents or embodies anything of value. 10. Tampering with the tangible property of one or. both of the parties, including any document that represents or embodies anything of value, and causing pecuniary loss to Counterpetitioner. 11. Selling, transferring, assigning, mortgaging, encumbering, or in any other manner alienating any of the property of Counterpetitioner or Counterrespondent, whether, personalty or realty,. and whether separate or community, except as specifically authprdzed by order of this Court. 3.2. Incurring any indebtedness, other than legal expenses in cpnnection with this suit, except as specifically authorized by order, of this Court, .13, Making withdrawals frpm any checking pr sayings account in any financial ipstitution for;' any purpose, except as specifically authorized by order of this Court. , 14. Spendipg any sum of cash in Counterrespondent' s possession or subject to Counterrespondent.' s ^control for any purppse, except as specifically authorized by order of this Court. 15. Withdrawing or .borrowing in any manner for any purpose frpm any retirement, profit-sharing, pension, death, pr other emplpyee benefit plan or employee savings plan or from any individual retirement account or Kedgh account, except as 5 specifically authorized by order of this Court. 16. Entering any safe-deposit box in the name of or subject to the control of Counterpetitioner or Counterrespondent, whether individually or jointly with others. 17. Withdrawing or borrowing in any manner all or any part of the cash surrender value of life insurance policies on the life of Counterpetitioper or Counterrespondent, except as specifically authorized by order of this Court. : 18. Changing or in any manner altering the beneficiary designation on any life insurance on the life of Counterpetitioner or Counterrespondent. 19. Canceling, altering, failing to renew or pay premiums, or in any manner affecting the present lever of coverage 'of any life,' casualty, automobile, or health insurance policies insuring the parties' property or perspng. ••;-;" • ' y20. Opening or diverting mail.addressed to Cpunterpetitiopgr. ,21. Signipg or endprsing Cpuhterpetitipher's hame on any negotiable instrument, check, pr draft, such ajs tax refunds, insurance payments, and dividends, or attempting to negotiate any negotiable instrument payable to Coupterpetitipner without the personal signature of Counterpetitioner.'. '.- .22. Taking any action fp terminate or limit.credit or charge cards in the name of Counterpetitioner. 23. Discontinuing or reducing the withholding for federal income taxes on Counterrespondent's wages or salary while this case is pending. 24. Destroying, disposing of, or altering any financial records of the parties, including but not limited to records from financial institutions (including canceled checks and deposit slips), all records of credit purchases or cash advances, tax returns, and financial statements. 25. Destroying, disposing of, or altering any e-mail or other electronic data relevant to the subject matters of this case, whether stored on a hard drive or on a diskette or other electronic storage device. 26. Terminating or in any manner affecting the service of wat^r, electricity, gas, telephone, cable television, or other contractual services, such as security, pest control, landscaping, or yard maintenance, at 1501 Olive,. JOurdanton, Texas 78026; 6026 Hazel Valley, San Antonio, Texas 78242 and/or 665 N. ;General McMullen, San Antonio, Texas 78228 or in any manner attempting to withdraw any deposits for service in connection with those services. •'''•'-;•." •*' '.-;':•'•• '27. Excluding Counterpetitioner from the use and enjoyment of the residence located at 1501 Olive, Jpurdantpn, Texas, 78026; 6026 Hctzel Valley, San Antonio, Te^xas 78242 andVpr .665 N. General McMullen, San Antonio, Texas 78228. 7 28. Entering, operating, or exercising control over the 2003 Saturn and 1998 Dodge Van in the possession of Counterpetitioner. Counterpetitioner requests that Counterrespondent be authorized only as follows: To make expenditures and incur indebtedness for reasonable and necessary living expenses for food, clothing, shelter, transportation, and medical care. To make expenditures and incur indebtedness for reasonable attorney's fees and expenses in connection with this suit. •:•': •;.'";••-To make withdrawals from accounts in financial institutions only for the purposes authorized by the Court's order. Counterpetitioner requests that Counterrespondent be ordered as follows: To make payments to the Counterpetitioner for the support Qf the Counterpetitioner pursuant to Texas Family Code; §6.502. To make payments of reasonable interim attorney's fees and expenses to Counterpetitioner's attorney pursuant to Texas, Family Code §6.502. ";-i .: 14. Request for Temporary Orders Concerning: Use.of'Property *'; . ;Counterpetitioner requests the Court, after, notice and hearing, for the preservation of the property and protection of the parties, to make; temporary orders and issue any 'appropriate temporary injupctions respecting the temporary use. pf the parties' property as deemed necessary and equitable, including but not 8 limited to the following: Awarding Counterpetitioner exclusive use and control of the 2003 Saturn and 1998 Dodge Van and enjoining Counterrespondent from entering, operating, or exercising control over it. Awarding Counterpetitioner the exclusive use of the following property and enjoining Counterrespondent from exercising possession or control of any of this property: her personal property, lawn tppls^'and 'any';pther/:items the; Court;, deems appropriate-, ' •'•'''''-'"'V ' 15. Request for Temporary Orders for Discovery and Ancillary Relief '\ Counterpekitiqner requests the Court, after notice and hearing, for the preservation of the property and protection of the parties, to make temporary orders for discovery and ancillary relief as deemed necessary and equitable, including but not limited to the following: Ordering .Counterrespondent to, provide,; a'..sworn.': inventory and. appraisement of §11 the separate/ and community property pwned'pr claimed by the parties' and all debts and liabilities owed bv. the parties substantially in the form and detail prescribed by the Texas Family L§w Practice Manual (3rd ed) , fprm 7-1. 16. Attorney's, Fees,:Expensesr Costs, and Interest It was necessary for Countefpetitipper to secure the services of EDWARD P. PIKER, JR^ a licensed attorpey, •%o prepare^ and prosecute this suit. To effect an equitable division of the*estate of the parties and as a part of the division, judgment for attorney's fees, expenses, and costs through trial and appeal should be granted against Counterrespondent and in favor of Counterpetitioner for the use and benefit of Counterpetitioner's attorney; or, in the alternative, Counterpetitioner requests that reasphable attorney's''fees, expenses/ and costs through trial and appeal be taxed a§ costs and be ordered paid directly t° Cpupterpetitioner's attorney, who may enforce the order in the attorney's own name, Counterpetitioner requests postjudgment interest as allowed by law. 17. Prayer Counterpetitioner prays that citation and notice issue as. required by law and that the Court grant a divorce and all other relief requested in this counterpetitipn. . ^•/- "- Counterpetitioner prays' that the Court, after notice, and hearing, grant this, request for, a temporary .injunction. -•VCounterpetitioperSprays fpr attorney's fees, expenses, costs', apd interest as. requested above. . ">"'••. .Counterpetitioner prays for general, relief. . Respectfully .'submitted, Edward P. Piker, Jr. 315 S, Main Avei -/- San Antonio, Texas.18204 Tel: (2*10) 226-0026." Fax: (210) 226-8402 10 UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION In re: Case No. 12-52696 G MANUEL GUADALUPE CASTRO JR. Debtor(s) CHAPTER 13 STANDING TRUSTEE'S FINAL REPORT AND ACCOUNT Mary K. Viegelahn, chapter 13 trustee, submits the following Final Report and Account of the administration of the estate pursuant to 11 U.S.C. § 1302(b)(1). The trustee declares as follows: 1) The case was filed on 08/31/2012. 2) The plan was confirmed on 11/26/2012. 3) The plan was modified by order after confirmation pursuant to 11 U.S.C. § 1329 on NA. 4) The trustee filed action to remedy default by the debtor in performance under the plan on NA 5) The case was dismissed on 10/03/2014. 6) Number of months from filing to last payment: 25- 7) Number of months case was pending: 33. 8) Total value of assets abandoned by court order: NA . 9) Total value of assets exempted: $15.445.93. 10) Amount of unsecured claims discharged without payment: $0.00. 11) All checks distributed by the trustee relating to this case have cleared the bank. UST Form 101-13-FR-S (9/1/2009) 033261 64204033294012 Receipts: Total paid by or on behalf of the debtor $20,000.48 Less amount refunded to debtor $2,812.32 NET RECEIPTS: $17,188.16 Expenses of Administration: Attorney's Fees Paid Through the Plan $2,700.00 Court Costs $0.00 Trustee Expenses & Compensation $1,181.52 Other $0.00 TOTAL EXPENSES OF ADMINISTRATION: $3,881.52 Attorney fees paid and disclosed by debtor: $500.00 Scheduled Creditors: Creditor Claim Claim Claim Principal Int. Name Class Scheduled Asserted Allowed Paid Paid ATASCOSA COUNTY Secured 1,569.41 1,298.30 1,298.30 0.00 0.00 ATASCOSA COUNTY Secured 402.66 420.84 420.84 0.00 0.00 Bexar County Clerk Unsecured 798.00 NA NA 0.00 0.00 BSI FINANCIAL SERVICES INC Secured 34,554.10 37,478.58 37,478.58 13,306.64 0.00 BSI FINANCIAL SERVICES INC Secured 222,286.00 251,847.20 251,847.20 0.00. 0.00 Bus & Prof Svc Unsecured 252.00 NA NA 0.00 0.00 City Employees Federal Unsecured NA NA NA 0.00 0.00 GENERATIONS FEDERAL CREDIT UN Unsecured 4,910.00 4,910.03 4,910.03 0.00 0.00 GENERATIONS FEDERAL CREDIT UK Unsecured 5,868.00 5,868.30 5,868.30 0.00 0.00 GENERATIONS FEDERAL CREDIT UK Unsecured 7,614.00 7,614.16 7,614.16 0.00 0.00 GREEN TREE SERVICING, LLC AS SE Secured 6,000.00 6,157.81 0.00 0.00 0.00 GREEN TREE SERVICING, LLC AS SE Secured 18,792.00 26,553.11 26,553.11 0.00 0.00 INTERNAL REVENUE SERVICE Priority 869.56 761.78 761.78 0.00 0.00 INTERNAL REVENUE SERVICE Unsecured NA 126.95 126.95 0.00 0.00 Med Data Sys Unsecured 113.00 NA NA 0.00 0.00 PALISADES ACQUISITION DCLLC Unsecured NA 234.95 0.00 0.00 0.00 UST Form 101-13-FR-S (9/1/2009) 033261 64204033294012 Semmary of Disbursements to Creditors: Claim Principal Interest Allowed Paid Paid Secered Payments: Mortgage Ongoing $0.00 $0.00 ' $0.00 Mortgage Arrearage $37,478.58 $13,306.64 $0.00 Debt Secured by Vehicle $0.00 $0.00 $0.00 All-Other Secured $280,119.45 $0.00 $0.00 TOTAL SECURED: $317,598.03 $13,306.64 $0.00 Priority Unsecured Payments: Domestic Support Arrearage $0.00 $0.00 $0.00 Domestic Support Ongoing $0.00 $0.00 $0.00 All Other Priority $761.78 $0.00 $0.00 TOTAL PRIORITY: $761.78 $0.00 $0.00 GENERAL UNSECURED PAYMENTS: $18,519.44 $0.00 $0.00 Disbursements: Expenses of Administration $3,881.52 Disbursements to Creditors $13,306.64 TOTAL DISBURSEMENTS : $17,188.16 12) The trustee certifies that, pursuant to Federal Rule of Bankruptcy Procedure 5009, the estate has been fully administered, the foregoing summary is true and complete, and all administrative matters for which the trustee is responsible have been completed. The trustee requests a final decree be entered that discharges the trustee and grants ,such other relief as may be just and proper. Dated: 05/21/2015 By:/s/ Mary K. Viegelahn Trustee STATEMENT: This Unified Form is associated with an open bankruptcy case, therefore, Paperwork Reduction Act exemption 5 C.F.R. § 1320.4(a)(2) applies. UST Form 101-13-FR-S (9/1/2009) 033261 64204033294021 SI mam- Services, inc. 10/09/2014 MANUEL G CASTRO JR 1501 OLIVE ST JOURDANTON, TX 78026-2220 Loan Number: 44675 Property Address:' 1501 OLIVE STREET JOURDANTON, TX 78026 NOTICE OF DEFAULT AND INTENT TO ACCELERATE Dear MANUEL G CASTRO JR: This letter is formal notice by BSI Financial Services, Inc. (herein as "BSI") the Servicer of the above-referenced loan, on behalf of MLB SUB I, LLC that you are in default under the terms of the documents creating and securing your Loan described above, including the Note and Deed of Trust/Mortgage/Security Deed ("Security Instrument"), for failure to pay the amounts due. The loan is due for 12/01/2011 and subsequent payments, plus late charges, fees and costs. As of today, the total delinquency and reinstatement amount is $73,967.02, which consists of the following: Next Payment Due Date 12/01/2011 Total Monthly Payments Due: $66,367.76 (35 @$ 1,732.72) Late Charges $4,204.26 Other Fees: $3,395.00 Unapplied Balance: ($0.00) TOTAL YOU MUST PAY TO CURE $73,967.02 It is possible that after payment of the amounts detailed above there may be other fees still due and owing, including but not limited to other fees, escrow advances or corporate advances that BST paid on your behalf or advanced to your account. This letter is a formal demand to pay $73,967.02. If the default, together with additional payments that subsequently become due, is not cured by 11/13/2014, BSI will accelerate the note so that the entire debt is immediately due and payable, and take steps to terminate your ownership in the property by a foreclosure proceeding or other action to seize the property. IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, BSI offers consumer assistance programs designed to help resolve delinquencies and avoid FORECLOSURE. These services are provided without cost to our customers. You may be eligible for a loan workout plan or other similar alternatives. If you would like to learn more about these programs, you may contact the Loss Mitigation Department at (800) 327-7861, Monday-Wednesday 8 am to 8 pm EST, Thursday 8 am to 6 pm EST, Friday 8 am to 5 pm EST, Saturday 8 am to 12 pm EST. WE ARE VERY INTERESTED IN ASSISTING YOU. The default above can be cured by payment of the total delinquency and reinstatement amount plus any TX_NOI Page 1 of 3 S2AiaM0ciM7 Comparative Market Analysis Property At: Prepared For: Manuel Castro 1501 Olive Jourdanton, TX 78026 \ Prepared By: *^_r* Archie Marmolejo _T All Season Realty 51HV>G SOUTH T53W5 AJI Season Realty Office Phone: (830) 281-5263 I Direct Line: (210) 347-7330 , Personal Fax Number: (210) 569-6211 Email: marmoiejoarchie@aol.com THIS IS A BROKER PRICE OPINION OR COMPARATIVEMARKET ANALYSIS AND SHOULD NOT BE CONSIDEREDAN APPRAISAL. In making any decision that relies upon my work, you should know that I have not followed the guidelines for development of an appraisal or analysis contained in the Uniform Standardsof ProfessionalAppraisal Practice of the Appraisal Foundation. Prepared By: Archie Marmolejo All Season Realty *^•vmjuxvi/ ""s • ••} ^-cm jcsiaie community Page 1 of 20 Comparative Market Analysis Property At: 1501 Olive Street Prepared For: Maryann Castro 1501 Olive Street Jourdanton, TX 78026 Prepared By: Karen Potts Dowdy Real Estate, LLC Office Phone: (830) 569-6883 DirectUne: (830) 569-6883 Personal Fax Number: Email: karen@dowdyrealestate.com rage iy ui zu Seller's Statement Property At: 1501 Olive Street Prepared For: Maryann Castro 1501 Olive Street Jourdanton, TX 78026 \ - Suggested Marketing Price: $184,000 c- \ - Comparative Market Analysis Property At: Prepared For: Manuel Castro 1501 Olive Jourdanton, TX 78026 > Prepared By: r* Archie Marmolejo _r All Season Realty o — cy^m«Vc%\f 4j 5EHTO.G SOUTH TsiWS All Season Realiy Office Rhone: (830) 281-5263 Direct Line: (210) 347-7330 Personal Fax Number: (210) 569-6211 Email: marmoiejoarchte@aol.com THIS IS A BROKER PRICE OPINION OR COMPARATIVE MARKET ANALYSIS ANDSHOULD NOT BECONSIDERED AN APPRAISAL. In making any decision thatrelies upon my work, youshouldknow thatI have not followedthe guidelines fordevelopment ofan appraisal or analysis contained in the Uniform Standards of Professional Appraisal Practice of theAppraisal Foundation. Prepared By: Archie Marmolejo All Season Realty Seller's Statement Property At: Prepared For: Manuel Castro 1501 Olive Jourdanton, TX 78026 Suggested Marketing Price: $351,375 fl5 flUUrtW Iftlit tlUH I bflUC. rax:ziuo/>uouu LOCATED AT: } J 816S FM 2146 j 9.45 Acres. J. Poitivem Survey ff1. Abstract 123' Jourdanton, TX 78026 } ill FOR: ' Advantage Mortgage 6601 Blanco Road. Suits 100 San Antonio, Texas 78218 AS OF: December 19,2006 BY: Angela R. Overlay 13730 Adobe Walls Drive Helotes. Texas 78023 (210)696-4400 Form IIA1 —TOTAL forWindows" appraisal softsai?by5 lamods, inc.—1-800-ALAMODE 1 U L. 1'IVIl l u n u L V Castro, Manuel Uniform Residential Appraisal Report Fte#8308 comparable properties ci nanHy offered for sain in the subject neighborhood ranging in price fmm t 225.000 toS 255,000 comparable sales in Hb iabject nelgtiborhood wiitrJa tie past twelve months rawing in sale price tram S ??citnm 240,000 earcli G did El did not reveal any pri ir sales or transfers ofHie comparable sales for the year pilot Mthe date of sale ofthe comparable sale. Pah joimefs) San AntonioMLS Repoa£ tha resultsITEM nf the research aim anajyin of fw(*i prior sale ortransfer in irn-r ~ \ historyn<-u>n of (liemm. subject- *«.— property.... and comparable I **. sates (report additional prior sales on page 3).1_ _._.-....-—t~—*-*————t ITEM SUBJECT COMPARABLE SAUiiH COMPARABLE SALE #g COMPARABLE SALE #3 Dateof PriorSale/Transfer See Con mania Price of Prior Sala/Tfansfer Below. None None DaTaJource(s)~ Effecttre Dale of Data Sourest;! Arcjlyte nf priorsaleortransfer history ofttieSidjtect property and comparablesafes The subject is undarconstruction and has nottransferred in the nasi as period. Thesales month period. used inthisaoi The sales U3ad raisal havenottransferred in this am iraisal have not transfeirprf inthe in tti« 12months prior in 19 mnnth^ ndnr to fho theabovenotedtransaction. ahmn nntori fran^ofj^n Sirnirrfary of Sales Comparison Approach Eqi al empha3ls was qivan all salea. Sale 1was superior In acreage and metal work shop. It was inferior in ago and EvTnq area. Sale 2 was inferior inac eaaa and aaa. butsunerior inbaths.IMno ansa,oarage and swimming pool. Sale 3 was oqualIn site site. butIterior Si value because itwaa locat idoutin thecounty. Itwas superior in baths, livinq areaand oarage. It wasnacassarv tousesalesthat closed"over 6 monBis agoandtogoovt r6 miles for comparable salesduetothalow density ofdevelopment In thesubject's maiftat araaand the need*for home sales on acreage tracts. The3ubiectis considered a "mini ranch" and those typesof residential properties are becoming increasingly pijai in tha ntettet popular 1 I Mealed Value by Sales Comparison Approach $ 225,000 Indicjtad Value by; SafesCompaiisonApproa Hi j 225,000 CostApproach(lfdevBliH)a™. 3. fme appraiser [dentified in this ippraisal report is either a sub-contractor or anemployee of the supervisory appraiser for the appraisal firm), is qualified to perfo am tt» appraisal, and is acceptable to perform this appraisal under the a^icabl^f Mte taT i 4. (This appraisal report complies promulgated by the Appraisal Standards dards Board of The Apprarsal Foundation and that were In place at the time this appraisal report was prepared. S. ff this appraisal report was transmitted defined in applicable federal and/oi "eStVi™,^/ electronic record containing my "electronic signature," asthose terms are state laws (excluding audio and video recordings), ora facsimile transmission of this appraisal report containing a copy >r representation of my signature, Hie appraisal report shall be as effective, enforceable and valid as if a paper version of this appraisal report wera delivered containing my original hand written signature. SUPERVISORY APPRAISER (ONLY IF REQUIRED) Signature ___ Name CompanyName Oyerley Appraisal Se rvices. Inc. Company Name Gomfjany Address T3730 Adobe Wal s Drive Company Address HelojaS, Texas 78023 Teleriftone Number (210> 695-4400~ Telephone Number EmalfAddress anqelaovertav(g)S3fa.rr EmailAddress Date bf Signature and Report Decen her 2a. 2005 Date of Signature _ Effecbve Date of Appraisal DacembiM9,2QQ5 State Certification # StaiBperBficaflbn # 1326255-r or State License # orState-Ucsrtse# State of Otter (describe) ______ . State #* ExpirationDate of Certification or License SSf3j___. fitpirafioh Dateof Certification or Licer se 06/30/06 SUBJECT PROPERTY 1 1 ADDRESS OF PROPERTY APPRAISED 1501 Ollva St i street Joun ianton, TX 7S026 APPF AISED VALUE OF SUBJECT PROPERTY $ 225.000 rop8rty LENlfcR/CUENT Name Sabriha RanallWall Cornfany Name AdvantageMortoana l Comf any Address 6601 Blanco Roac Suite 100. San Antonio, , from street Teotas 78216 f.k.* m street Email Address sranalliOloqixanllrte-COi n -*iM Freddie Mac Form 70 March 2005 Page 6 of 6 Fannie Mae Form 1004 March 2005 Form 1004—"TOTAL'tor Windows" appraisal software by ala mode, inc. —1-800-ALAMQQE Statement of Account NOTICE: This is a statement of Taxes Due as of 06/01/2015 12:26:57PIV1 based upon the tax records of the tax office. ATASCOSA COUNTY TAX OFFICE Property Information 1001 OAK STREET Property ID: 17471 Geo ID: 01239-00-000-001104 JOURDANTON, TX 78026 Legal Acres 9.4500 Legal Desc: ABS A01239 J POITEVENT SV-1,9.45 ACRES Situs: 1501 OLIVE ST , DBA: Exemptions: DP, HS Owner ID: 87397 Ownership: 100.00% Value Information CASTRO MANUEL & MARYANN Improvement HS: 159,770 PO BOX 495 Improvement NHS: 0 Land HS: 54,810 PLEASANTON, TX78064 Land NHS: 0. Productivity Market: 0- Productivity Use: o: Assessed Value 214,580 Entity Description Pet. Ex Code Description FMLR FARM TO MARKET ROAD 100.00% DP Disability GAT ATASCOSA COUNTY 100.00% HS Homestead SJO JOURDANTONISD 100.00% WEV EVERGREEN WATER DIST 100.00% Unpaid Bills Summary Entity Year Statement ID Tax Rate Type Tax Due Disc/P&l Attorney Fees Total Due FMLR 2013 53838 0:076000 L 87.22 25.30 16.88 129.40 GAT 2013 53838 0.340600 L 395.84 114.79 76.59 587.22 WEV. 2013 53838 0.006000 L 6.24 1.81 1.21 9.26 Total for Year 2013 489.30 141.90 94.68 725.88 Total For All Years 489.30 141.90 94.68 725.88 Total Due if Paid By 06/30/2015 725.88 Paid Refunds Summary No Information on File. *** End of Statement *** NOTICE: This document is not a tax certificate and does not absolve a Taxpayer from tax liability in any way. If this document is found to be Page 1 in error, it may be corrected by the Collection Office listed above. Responsibility to pay the remaining taxes rests entirely with the Taxpayer, True Automation. Inc. as outlined in the Texas Property Tax Code. Homes Mortgages Agents Local News Fisrffipj'^iHyTijffffl^ijift —1 .. City, Zip, Neighborhood, Address orMLS# search San Antonio Metro Area > 78026 > 1501 Olive Street, Jourdanton, TX 78026 1501 Olive Street Jourdanton, TX 78026 $216,240 $292,560 LOW $254,400 HIGH ^ /ALUE ESTIMATE Value Estimate $254,400 ? Beds Payment Estimate $959/mo ? Baths Full Rent Estimate $1,700 ? Baths Half Tax Estimate $3,281 ? Sq Ft 2,404 /^s HomeScore 40 ? Lot Size 9.00 •^ InvestorScore 34 ? Construction Last Sale Date 08/25/2000 Style Last Sale Price -- Year Built 2005 i^st Hom€?snnj^ NotaryTublic, State of Texas ^{iX GINA S. VIUAGOM6Z l*XJbF% Notary Public. Stale ofTe«s \"»\A\A* My Commission Exoi'es $fcw '"•:„",:«--v' ' • Februory 27. 2017 ~&> Affidavit ofMaryAnn Castro Page 2 1UNITED^STATES Official Change Of Address 'POSTAL SERVICE, gMnfirm^tion LETTER VERIFICATION REQUIRED YOUR OLD ADDRESS aw © © Mail will be forwarded for the MARYANN CASTRO following individual only: 23302 HICKORY SHADOW Z MARYANN ELMENDORFTX 78112-6172 CASTRO Your mail will be forwarded to your NEW address, as you requested, —I o on: Sep 30,2014 m i— o YOUR NEW ADDRESS •5o 00000067002 MB 0.435 T:0004 Ifthe information contained on this page is incorrect, or you have not received mail at your new address for 10 Postal business days or more, please call 1-800-ASK-USPS •Mill II lli'lll'-ll'l'll1'!""1'''-!!!'!!"' (1-800-275-8777). MARYANN CASTRO If you need to view or cancel this PO BOX 495 > CO Change-of-Address Order or change the PLEASANTON TX 78064-0495 date to start forwarding your mail,visit managemymove.usps.com and enter the Confirmation Code: 1429 45011010 9450 m Visit managemymove.usps.com to add your JO email address and receive email reminders CO of mailforwarding expiration dates. NOTIFY CORRESPONDENTS MAIL FORWARDING EXPIRATION DATES WHO SENO YOU MAIL Mail forwarding may be available First Class Mail, Priority & Express.... Sep 30,2015 for up to 12 months and covers Newspapers, Magazines Nov 29,2014 only certain classes of mail. Packages' Sep 30,2015 To ensure delivery of all your mail Catalogs Not Forwarded2 and to avoid forwarding delays, Standard Mail Not Forwarded2 you should notify everyone who 1. Some restrictions apply 2. Unless requested by mailer sends you mail. IMPORTANT MESSAGES FROM THE U.S. POSTAL SERVICE REGARDING YOUR MAIL FORWARDING REQUEST: WHY THE YELLOW LABELS? Yellow labelsjihdicate the=,'::.#.j Yellow stickers with your new address are placed on mail correspondent doesn't know, forwarded by the U.S. Postal Service, To receive your mail faster, your new*a3dfessT?'!r''••i--;';*''-l'di notify the sender of your new address. If you receive maiUwith a Please retain this Official Change of Address Confirmation page yellow label attached, notify the for your records as local agencies and/or resources may require it sender of your new address. for proof of your move. ..UU.JU. ,nh^U«..MU*»f*^^ All of the paper used to produce the USPS'" Official Change of Address Confirmation Letter was sourced from sustainable forests. 1 i n n 1 i m nnnn i i i n n i i n i n <^,i7.nRfi_nnnnfi7n Wells Fargo Home Mortgage s$ZW^M£m^& 1 Home Campus lllllllll^ Des Moines, IA 50328-0001 mm.GOimQiR'TBM'&Mi October 15,2013 MANUEL G CASTRO JR 23302 HICKORY SHADOW ELMENDORF TX 78112-6172 Subject: Transfer ofthe servicing-.ofyour mortgage loan Wells Fargo Home Mortgage loan number: 015CJ04467JM Dear MANUEL CASTRO JR, Effective November l,2013 the servicing ofyour mortgage loan is being transferred to BSI Financial Services, Inc. While the transfer ofservicing is very common intoday's mortgage industry, we recognize itoften raises a number of questions. Since you may have questions about this change to your mortgage servicing, we're providing you with information to help make this transition easier for you. Rest assured, this does not affect any terms or conditions ofyour mortgage. This transfer simply affects how your mortgage is serviced, like where you send your payments. Please read the reverse side ofthis letter - The Notice ofAssignment, Sale orTransfer ofServicing Rights provides you with important required Real Estate Settlement Procedures Act (RESPA) information. Important payment information Beginning on November 1, 2013, BSI Financial Services, Inc will begin receiving payments on your mortgage loan As ofthe same date, Wells Fargo Home Mortgage will no longerbe accepting payments on such mortgage loan, thereforeyou must make yourloan payments payable to BSI Financial Services, Inc and send them to the following address: BSI Financial Services, Inc ' P.O.Box660605 Dallas, TX 75266 BSI Financial Services, Inc will be sendingyou aletter that will include payment ™s^fon*-^™J°™L receive payment instructions from BSI Financial Services, Inc before your next payment is due, please write rourlo^xXr onyour checkor money order and mail it to BSI Financial Services, Inc at the address listed above. • notify them ofthechange in servicer. ^oU ha^wSJpSS)fMA Package, transfer ofyourWells Fargo servicedmortgage loan may eliminate S aMuT10 hnk^your mortgage to your PMA qualifying relationship balance and may result myour combined S^fiSS^the mmimum requiredfor the PMA Package monthlyservice fee waiver as well as certain other PMA benefits. Wells Fargo Home Mortgage isadivision ofWells Fargo Bank, N.A. NMLSR ID 399801 Page 1 of 3 :WELLS Return Mail Operations Statement date 01/13/12 POBox 14411 FARGO Des Moines, IA 50306-3411 Loan number 0150044675 Property address 1501 OLIVE STREET JOURDANTON TX 78026 Customer Service __ online For informational purposes W i—i Fax ' yourwellsfargomortgage.com 1-866-278-1179 7JrJ Telephone 1-800-274-7025 Correspondence •|]|l'"'lll[|hllTlll"TH hl'"| -IS'i'-E-'i-I-miI PO Box 10335 Hours of operation Mon - Fri 7 a.m. - 8 p.m CT Des Moines, IA 50306 1AB 00471/024.131/001039 0109 3 ACP8GI 708 1 Q IPayments MANUEL G CASTRO JR ; PO Box 660455 1501 OLIVE ST Dallas TX 75266 JOURDANTON, TX 78026-2220 We accept telecommunications relay service calls.. Important messages This statement is for informational purposes only. Summary Our records indicate tb.at.your loan is subject to - Payment (principal and/or interest, escrow) $1,745.85 Unpaid principal balance bankruptcy. The attached coupon reflects the Current monthly payment 02/01/12 a-. 7/c pc Unpaidadvance balance calendar due date, not the contractual due date of Unapplied balance the bankruptcy case. If you have any questions Overdue payment(s) 04/01/11 - 01/01/12 $17,445.36 (ContactCustomer Serviceforyourpayoff balance) regarding your loan, please contact your Interest rate 6.950% Unpaid late charge(s) $1,080.26 Interest paid year-to-date $1,288.99 bankruptcy attorney or our office. Other charges $340.00 Escrow balance $1,154.82- Total payment 02/01/12 $20,611.47 Activity since your last statement This statementis forinformational purposes onlyand is beingprovided asa courtesy should youvoluntarily decide to make your loan payments.Thisstatement should not be construed as an attempt to collect a debt or a demand for payment contrary to any protections you may have received pursuant to your bankruptcy case. Ifyouhave receiveda discharge, andthe loanwasnot reaffirmedin the bankruptcycase,wewill onlyexerciseour rights as against the propertyandweare not attemptingany act to collectthe discharged debtfrom youpersonally. Ifyour Planrequiresyouto makeregularpost-petition mortgagepayments directlyto the Bankruptcy Trustee, and you chose to maintain your mortgage payment, any payment should be remitted to the Trustee or otherwise in accordance with the Plan you filed with the Bankruptcy court. Date Description Total Principal Interest Escrow Other 01/13 Payment $273.07 $1,288.99 $183.79 Unapplied $1,745.85- 01/12 Funds received $1,700.00 Unapplied $1,700.00 12/08 Funds received $1,700.00 Unapplied $1,700.00 Continued on the next Daae 024181/001039 ACP8GI S1-ET-M1-C009 1 Monthly payment Loan number 0150044675 x pint arnt WELLS FARGO Additional principal Check here and see MANUEL G CASTRO JR • Late r «~ reverse for address charaes ~ ^ correction. 00471/024181/001039 0109 3 ACP8G! 708 Please specify additional funds Otha D *£ .harges |D|'i>i|ii|iiiiii||hi-ii'|iii'|'ii|igi'-'»'|'i-ii|i| iir WELLS FARGO HOME MORTGAGE PO BOX 660455 '"• Additional DALLAS TX 75266-0455 Total amount enclosed (Please do not sand cash) "•? 70A D1SDDM-MW7S 2 lDDDD17MSflSDlflS3,:iS2Dbim71c]niEl DDDDDDnDflDSSBiaTD? D L J' YOUR OLD ADDRESS f ' will be forwarded for the MARYANN CASTRO fdiiuwing individual only: 23302 HICKORY SHADOW m MARYANN ELMENDORFTX 78112-6172 S3 CASTRO m Yourmail will be forwarded to your an NEW address, as you requested, —I o on: Sep 30,2014 zn m r— o YOUR NEW ADDRESS o O 00000067002 MB 0.435 T:0004 30 Ifthe information contained on this page is OO incorrect, or you have not received mail at your new address for 10 Postal business days or more, please call 1-800-ASK-USPS Ihll'HIII lli'in>ilm!i>Ml>l'i"«><»«ii!'ii"i g I— (1-8QQ-275-8777). MARYANN CASTRO cz PO BOX 495 > Ifyou need to view or cancel this ro Change-of-Address Order or change the PLEASANTON TX 78064-0495 r— m date to start forwarding your mail, visit managemymove.usps.com and enter O the Confirmation Code: 1429 450110109450 m Visit managemymove.usps.com to add your email address and receive email reminders CO of mail forwarding expiration dates. •A.. c *."\ BEXAR BOUNTY SHERIFF'S OFFICE L i. fReqwetf forrSheriffs Report RV4/04 350-135 DATE rfnfi\ District: ^cy^JCaseNo. ;/_ 3g5^ Name of Complainant: Location^Incident: £%^j /jl£ (4(j £)\<%iloU>* Type of Incident: 'fc'i^Ktr'j^vT^ Sheriffs Deputy Badge Phone: 2/A j APPGILG^ NOTE: If you wish to pursue criminal charges, please contact the Criminal Investigations Division at (210)335-6070 ~"JT: «$• CyflM'ti fL.ur Ifyou have questions or concerns in thefuture regarding workout options )r status ofthe loan, please" contact! ourBankruptcy Department at (800) 274 Representatives are available for assistance Monday through Friday, 7 a.m Time. Wells Fargo Home Mortgage is committed to serving the needs of our cusfc any additional questions or need clarification regarding the information pn contact me directly at (877) 491-0707, extension 65129. I am available to a: through Friday, 9:00 a.m. to 6:00 p.m., Eastern Time Sincerely, m^.z^H Rita Reilly Written Customer Contact Enclosure ->: *hfLDd^Pte^iao^ -process y>c\s\y^q^ap^a^ We understand that your clients have filed for bankruptcy. We are not not attempting attemptii to collect the mortgageage debt with this letter. Wefe are required required I by federal law to inform you that if your client's loan is currently delinquent or in default, as the loan servicer, we will be attempting to collect a debt, and any information obtained will be used for that purpose. However, this letter should not be construed as an attempt to collect a debt or a demand for payment contrary to any protections provided by the automatic stay of your client's bankruptcy case. If your clients have received a discharge, and the loan was not reaffirmed in the bankruptcy case, ;ase, we we will will only exercise our rights as against the the property and and are are not not attempting vS »'l-m Yprocess i /\OeM&tJ ^v> 04/W' No Data Available K^ Amount Amount Due *&&* S 03/^ $1,732 2/1/2014 $220,615 Conventional Re Mortgage Additioftatlhtornriattopu Loan Modified; 180 Days or More Past Due $258,108 61,732 $1,733 2/1/2014 $220,615 "Conventional Re Mortgage ^ itictiiahnJQ^atio'ri: Loan Modified; 180 Days or More Past Due pr^^^-^^-^^^^^ (Continued On Next Page) Page 5 of 62 4148034000010-001658549- 1641 - 2188 - ASD w 12-52696-cag Doc#61 Filed 07/29/14 Entered 07/29/1416:34:44 Main Document Pglof3 UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION § CASE NO.: 12-52696G IN RE: - W + MANUEL GUADALUPE CASTRO JR. § fl § 1 , ih Debtor § 1.. . (' , • ••'.•:, TRUSTEE'S AMENDED OBJECTION TO MOTION TO J .«•. APPROVE AGREEMENT FOR FINAL DIVORCE NUNC PRO TUNC AND REQUEST FOR HEARING ! TO THE HONORABLE JUDGE OF SAID COURT: Now eon**, Mary K. Viegeiahn, Chapter 13 trastee and files ftis, her Cnapfcr 13 Tree's Amended Objection to the above-referenced Motion. The Chapter 13 Trostee does not approve the afore-mentioned motion for the following reasons: neTra5<~oPpc*es,heMon=^ ^^tSS*S?SSSZt^r^le o7the home at ,501 Olive St Joardanton SS^SIrtSK£ Sep.en.ber 21.»I2 reacts ava.ue ofS2353W.00with secar* c^orW*,! and the Detaor -£^£^£^1^%£. wrdVtt leaving the Debtor with non exempt tunds ot azo^^i. *"* £££ tf toCuIn on Debtor's Scheduis A«. _~ and fuestions 4= good fa* of the Debtor's valuation on Schedule A. TheMotion does not state how the mortgage arrears currently being paid*™^*D*^^ I^rwill be treated. The Trustee questions who will poperty wilt de be taking over the funding of tins Popa* disbursements on the mortgage arrears to BSI .neluding *>""W ^be7g^ by through the plan. The property settlement agreement has disbursed $7,347.09 to BSI Financial Services Inc. for the arrears. * ,r+~-r, on rvrnher 10 2012 the Debtor was advised that a Motion to Lift the T IS«Ssti°wingthe exeeotion ofthe property sett.en.en. on October 30,2013. As without prior approval ofthis Court. IT IS HEREBY ADJUDGED and DECREED that the below described is SO ORDERED. Dated: October 03, 2014. CRAIG A. GARGOTTA UNITED STATES BANKRUPTCY JUDGE IN THE UNITED STATES BANKRUPTCY COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION IN RE: § CASE NO. 12-52696-G § § Manuel Guadalupe Castro, Jr. § § § DEBTOR(S) §§ CHAPTER 13 ORDER APPROVING MOTION TO VOLUNTARILY DISMISS CHAPTER 13 CASE On this date came on to be considered Debtor's Motion to Voluntarily Dismiss Chapter 13 case. The Court finds that such motion states sufficient grounds to be approved and that Debtor has the right to voluntarily dismiss this case, without prejudice, as it has not been previously converted from another chapter of the Bankruptcy Code. It is, therefore, ORDERED that Debtor's Chapter 13 case be, and the same is hereby DISMISSED without prejudice to re-filing. ### Davis Law Firm 10500 Heritage, Ste. 102 San Antonio, Texas 78216 (210)444-4444 012362 77704012374017 w 12-52696-cag Doc#63-l Filed 09/04/14 Entered 09/04/14 20:37:39 Affidavit Pg 2of 35 4. Manuel G. Castro Jrand Mary Castro executed a Adjustable Rate Note dated March V, 2006. in favor ofWells Fargo Bank, N.A. in the original principal sum of SI 91 ?50 00 ' (the '"Note"). 5. BSI FINANCIAL SERVICES. AS SERVICER FOR WELLS FARGO BANK, NA is ths servicer of the loan and holds the Note. Hni __(). The Note is secured by aRecorded Deed ofTrust encumberinc certain real property commonly known as 1501 OLIVE STREET. JOURDANTON" TX 78026. *ra>fe, The unpaid principal balance ofthis loan as ofAugust 26.2014 is 5220,897.72. 8. The ratal post-petition arrearage due as of August 26, 2014 is 542.411.76. Please note that additional payments will come due after September" I.'2014. Attiichea hereto as ^ee, Exhibit "A" is asummary of the Debtor's post-payment history, including default dates and amounts. 9. The sums set forth in this affidavit do not include any late charges, escrow advances attorneys- fees, cost, orother fees and charges that might otherwise be included in the event that a payoff is requested or provided. 10. The Note, and Supplemental Riders. Amendments, Modifications, Deed of Trust and Assignments, ifany, are attached hereto as Exhibit "A" and are true and accurate copies of the originals. Further Affiant Saved! Not. BY: AFFIANT Subscribed and s"*om to before me s thisjjj^day ofifefrffi2014- by U 'iftjiZIfl&Jjtfi State of "PR^Q.^ My Commission expires: 3/ | / \f Personally Known fej OR Produced Identification , Type of Identification Produced: w 12-52696-cag Doc#63-l Filed 09/04/14 Entered 09/04/14 20:37:39 Affidavit Pg 2 of 35 anuel G. Castro Jrand Mary Castro executed aAdjustable Rate Note dated March 07, 2006. in favor ofWells Fargo Bank, N.A. in the original principal sum of$19 J ?50 00 (the "Note"). BSI FINANCIAL SERVICES. AS SERVICER FOR WELLS FARGO BANK, N.A. is th servicer of the loan and holds the Note. 6. The Note is secured by aRecorded Deed ofTrust encumberine certain real property commonly known as 1501 OLIVE STREET, JOURDANTON" TX 78026. 7. The unpaid principal balance ofthis loan as ofAugust 26.2014 is 5220,897.72. 8. The rata! post-petition arrearage due as of August 26, 2014 is 542.411.76. Please note ^rOv_-> that additional payments will come due after September I, 2014. Attache3 hereto as *^X Exhibit "A" is asummary of the Debtor's post-payment history, including default tlsKd<-A dates and amounts. *—^%^U S\* 9. The sums set forth in this affidavit do not include any late charges, escrow advances. * attorneys" fees, cost, orother fees and charges that might otherwise be included in the event that a payoff is requested or provided. JO. The Mote, and Supplemental Riders. Amendments. Modifications, Deed of Trust, and Assignments, ifany, are attached hereto as Exhibit "A" and are true and accurate copies of die originals. Further Affiant Saveth Not. BY: AFFIANT Subscribed and sworn to before me i lhis^L_dayoffWWir20(4, by tfafll'M. State of "P*Xfl.^ My Commission expires: 3/ j / \f Personally Known pj OR Produced Identification . Type of identification Produced: —o9o-,aS Doc.63 ^09/04*4 Enters 09/04/1420.37:39 dSL *,J! Wft v°w.- **»0""ab' For »Rel, "Aug>« 31.2012. MANUEL GOADALUPE CASTRO » rf under Chapter 13]3 ofrf the Bankruptcy Code, CASTR° Vu *•"-***»**.a therebv -.,- . tyk"J&, Bankruptcy Case. MARYK VlFTFf amm • , '' ^ * *"**«« IARVK. VIEGELAHN -he duly appointed andacting Chapter 13 W !-F' ' 4- On March 07,2006 Vfami^i r r . , " ' mUd °- C"S,m Jr HK«WAojustabie RaK NoK ,. ... ., . . s P"naP"mOUn,0fS]9,J5^^*»*"*„fWe,lsFaioBM)tN/, —«^- : May Castro is no, .c,b,ormth,statn,p,cy,ta;sprottciedbyiheC adehor ir,«,-. K . Payn,a" °f "" N<*=- iSHSIH^™™=StK*? °* —* C0UNTY ATTACHEDTOT„EDEE«^V^ AND BEING MADE PARTTCuJ^frS^^Jf,***»; Also known as: 1501 OLIVE STREET JOURDANTON, TX 78026 The Deed ofT^twas duly recorded inATASCOSA County DeedRecords. * Debtor alleges to be the ««* owner ofrecord ofAe Property ^ __ ,^ provides for direct ongoingpayments. ^ ^ 13 P,a» 7- Debtor is i„ defauJt „ & .^^ 8- As ofAug™ 26.20I4. *estMlsoffte ^ ^ ^bMmb_ c "•«»* ^^P«PaIWanKd.ffl(lowingtoMovanton theNi b) "" am0m*™*="Vlool practice, rote, or order. NO. 2011-CI-15957 IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF § MANUEL G. CASTRO § 45 JUDICIAL DISTRICT AND § MARY ANN CASTRO § BEXAR COUNTY, TEXAS ORDER ONMOTION TQ DECLARE AGREEMENT FOR FINAL DIVORCE VOTD On September 1.6, 2014 and September 29, 2014, the Court heard Movant Mary Ann Castro's Motion to Declare Agreement for Final Divorce Void. Movant Mary Ann Castro appeared in person and by attorneys ofrecord, Sarah Anne Lishman and Jamie L. Graham, and announced ready. Respondent Manuel G. Castro appeared in person and by attorney of record, Joseph Appelt, and announced ready. The Court finds that the "Agreement for Final Divorce" was orally pronounced and rendered by Judge David A. Canalles on October 30, 2013. The Court further finds that the "Agreement for Final Divorce" was approved by the bankruptcy court in Cause No. 12-52696 on July 31, 2014, and THEREFORE ORDERS that the Motion to Declare Agreement for Final Divorce Void is DENIED. All relief not expressly granted is DENIED. SIGNED ON JUDGE LAURA SALINAS Order on Motion toDeclare Agreementfor Final Divorce Void: Castro Page 1 12-52696-cag Doc#63 Filed 09/04/14 Entered 09/04/14 20:37:39 Main Document Pg 3 of 5 III. RELIEF FROM THE STAY .9. Movant requests that this Honorable Court terminate the automatic stay provisions of tile Bankruptcy Code to allow Movant to exercise all of its rights and remedies against the Debtor and Co-Debtor under state law, including, inter alia, foreclosing its lien onthe Property. 10. Movant alleges that cause exists for the lifting of the stay__and Movant's interest is not adequately protected. 11 U.S.C. § 362(d)( 1). The assessed value byAtascosa Cou It has been necessary for Movant to hire the law firm ofCodilis &Stawiarski, P;C. to collect the debt owed to it through this Court. Pursuant to the Note and Deed of Trust, Movant is entitled to reimbursement ofits reasonable attorneys' fees for their services. 12. Movant requests that an Order granting its motion for relief from automatic stay and Co-Debtor Stay, ifsttch Order should be entered, will be etfective immediately upon entry and. Rule 4001 (a) (3), is waived, and enforcement ofsuch Order will not be stayed until the expiration offourteen days after entry ofthe Order. 13. Movant further requests that upon termination ofstay, it be exempt from further compliance with FRBP 3002.1. WHEREFORE, PREMISES CONSIDERED, Movant prays that this Court enter an Order granting relief from the automatic stay to allow Movant to exercise and enforce all its rights and remedies against the Debtor and Co- Debtor as a secured creditor and perfected lienholder to the Property; including, but not limited to, payments of bankruptcy attorney lees and costs in the amount of S800.00, foreclosure and disposition of the Property, payment of costs, expenses, and reasonable attorneys' fees inaccordance with the terms ofthe Note and Deed ofTrust and for such other and further relief to which Movant may show itselfjustly entitled, either at law or in equity. Respectfully submitted, Codilis& Stawiarski,P.C. By: Isl Angela K. Randermann Angela ft. Randermann SBOT 24029787 (31688) Yvonne V. Valdez SBOT 24069019 650 N. SamHouston Parkway East,Suite450 Houston, Texas 77060 (281) 925-5200 Facsimile: (281) 925-5300 ATTORNEYS FOR MOVANT BUCKLEYH madole Buckley Madole, P.C. 14841 Dallas Parkway, Suite 425 Dallas, TX 75254 Main: (972)643-6600 Fax: (972)643-6699 LEGAL PRECEDENT IS NOT CLEAR AS TO WHETHER THE SENDING OF THIS LETTER MAKES US A DEBT COLLECTOR. TO THE EXTENT IT DOES, PLEASE BE ADVISED THAT THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. HOWEVER, IF YOU ARE IN BANKRUPTCY OR HAVE BEEN DISCHARGED IN BANKRUPTCY, THIS LETTER IS FOR INFORMATIONAL PURPOSES ONLY AND IS NOT INTENDED AS AN ATTEMPT TO COLLECT A DEBT OR AS AN ACT TO COLLECT, ASSESS, OR RECOVER ALL OR ANY PORTION OF THE DEBT FROM YOU PERSONALLY. December 2,2014 MARY CASTRO 1501 OLIVE STREET JOURDANTON, TX 78026 Re: Loan No.: 44675 Property: 1501 OLIVE STREET, JOURDANTON, TX 78026 FAIR DEBT COLLECTION PRACTICES ACT NOTD7ICATION We represent BSIFinancial Services, Inc., whose address is 7505 Irvine Center Drive, Irvine, CA92618 which,.ifit is not the Current Mortgagee, is acting as the Mortgage Servicer and representing the Current Mortgagee pursuant to a Mortgage Servicing Agreement concerning the Note and Deed of Trust which are associated with the above referenced ioannumber. Our firm has been requestedto pursueforeclosure processingin accordance with the terms of the Note and Deed of Trust and applicable law. 1. According to the information provided to us by ourclient, thetotal amount required to curethe default under the note and deed oftrust through December 15, 2014 is $79,019.30 and the total amount required topayoff the debt through November 30,2014 is $275,251.54. 2. Because ofpayment installments that accrue monthly and other charges that may vary from day to day, the total amount required to cure thedefault may be greater on theday thatyou choose to pay. Likewise, because of interest and/or other charges thatmay vary from day to day, thetotal amount required topayoffthedebt may begreater onthe day that you choose to pay. Hence, should you choose topay either oftheamounts shown above, anadjustment may be necessary after your check is received in which event we will notify you before the check is deposited for collection. For further information, write our firm at Buckley Madole, P.C, Attn: Foreclosure Department, 14841 Dallas Parkway, Suite 425, Dallas, TX 75254 or call us at (972) 643-6600 . 3. You have thirty days afteryou receive this letter, to dispute the validity of the debt or any part of it. If you do not dispute it within that period, our firm will presume that it is valid. 4. Ifyou notify ourfirm inwriting within thethirty-day period that thedebt, or any portion thereof, isdisputed, ourfirm will obtain verification of the debt or a copy of ajudgment against you and a copy of such verification orjudgment will be mailed to you by our firm. Ifyou require further information, please let us hear from you. Very truly yours, i Buckley Madole, P.C. 1io-3g?-(o13c1 314 S Franklin St / Second Floor PO Box 517 Titusville PA 16354 BSI Financial 1-800-327-7861 814-217-1366 Fax Services www.bsifinancial.com April 27,2015 0iMi*> rruJL/^ MANUEL G CASTRO JR MARY ANN CASTRO 1501 OLIVE STREET x jT^O^A^ JOURDANTON, TX 78026 NOTICE OF SERVICING TRANSFER Account #: 44675 The servicing of your mortgage loan is being transferred, effective May 15, 2015. This means that after this date, a new servicer will be collecting your mortgage loan payments from you. Nothing else about your mortgage loan will change. BSI Financial Services is now collecting your payments. BSI Financial Services will stop accepting payments received from you after May 14, 2015. SN Servicing Corporation will collect your payments going forward. Your new servicer will start accepting payments received from you on May 15, 2015. Send all payments due on or after May 15, 2015 to SN Servicing Corporation at this address: SN Servicing Corporation • PO Box 602814 Charlotte, NC 28260-2814 Ifyou have any questions for either your present servicer, BSI Financial Services or your new servicer SN Servicing Corporation about your mortgage loan or this transfer, please contact them using the information below: Current Servicer: New Servicer: BSI Financial Services SN Servicing Corporation Customer Care Customer Correspondence 314 S Franklin St, 2nd Floor 323 Fifth Street Titusville, PA 16354 Eureka, CA 95501 1-800-327-7861 1-800-603-0836 Mon.-Fri. 8:00 a.m. - 11:00 p.m. EST Mon.-Fri. 8:00 a.m. - 5:00 p.m. PST Saturday 8:00 a.m. - 12:00 p.m. EST Licensed as Servis One, Inc. dba BSI Financial Services. BSI Financial Services NMLS # 38078. Customer Care Hours: Mon. -Thurs. 8:00 am to 8:00 pm (ET), Fri. 8:00 am to 5:00 pm (ET), Sat. 8:00 am to 12:00 pm (ET). Colorado Office Location: 13111 E. Briarwood Ave., Suite 340, Centennial, CO 80112 (303) 309-3839. Licensed as a Debt Collection Agency by the New York City Department of Consumer Affairs,(# 2001485-DCA). North Carolina Collection Agency Permit (# 105608). Ifyou have filed a bankruptcy petition and there is an "automatic stay" in effect in your bankruptcy case or you have received a discharge of your personal liability for the obligation identified in this letter, we may not and do not intend to pursue collection of that obligation from you personally. Ifeither of these circumstances apply,this notice is not and should not be construed to be a demand for payment from you personally. Unless the Bankruptcy Courthas ordered otherwise, please also note that despite any such bankruptcy filing, whatever rights we hold in the property that secures the obligationremain unimpaired. Page 1 of 2 NOTICE OF ACCELERATION AND NOTICE OF TRUSTEE'S SALE DEED OF TRUST INFORMATION: Date: 03/07/2006 Grantor(s): MANUEL G CASTRO JR, MARY ANN CASTRO Original Mortgagee: WELLS FARGO BANK, N.A. Original Principal: $191,250.00 Recording Information: Instrument 80487 Property County: Atascosa Property: BEING A 9.45 ACRE TRACT SITUATED IN THE J. POITEVENT SURVEY, ABSTRACT 1239, ATASCOSA COUNTY, TEXAS, AND BEING THAT SAME 9.45 ACRE TRACT AS CONVEYED BY THOMAS F. PERKS AND LOLA M. PERKS TO MANUEL G. CASTRO AND MARY A. CASTRO RECORDED IN VOLUME 152, PAGE 442, OFFICIAL PUBLIC RECORDS OF ATASCOSA COUNTY, TEXAS; SAJD 9.45 ACRE TRACT SURVEYED BY JEFFREY B; BERGER, R.P.L.S. NO. 5558 ON AUGUST 19, 2005 AND BEING MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT A 1/2" STEEL ROD WITH A RED PLASTIC CAP STAMPED "RPLS 5558" ON THE NORTH LINE OF COUNTY ROAD 438 (ALSO KNOWN AS OLIVE STREET) AT THE SOUTHWEST CORNER OF THE REMAINING PORTION OF A 106.23 ACRE TRACT AS RECORDED IN VOLUME 78, PAGE 430, DEED RECORDS OF ATASCOSA COUNTY, TEXAS, FOR THE MOST SOUTHERLY SOUTHEAST CORNER OF THE HEREIN DESCRIBED TRACT; THENCE SOUTH 89 DEG 54" 00" WEST 509.51 FEET (BASIS OF BEARINGS) WITH SAID NORTH LINE OF COUNTY ROAD 438 TO A STEEL FENCE CORNER POST AT THE MOST SOUTHERLY SOUTHEAST CORNER OF THE EUGENE C. JUPE FAMILY LIMITED TRACTS AS RECORDED IN VOLUME 251, PAGE 537 AND VOLUME 251, PAGE 543, OFFICIAL PUBLIC RECORDS OF ATASCOSA COUNTY, TEXAS, FOR THE SOUTHWEST CORNER OF THE HEREIN DESCRIBED TRACT; THENCE NORTH 00 DEG 40" 00" WEST 405.38 FEET ALONG A WIRE FENCE WITH A COMMON LINE OF SAID 9.45 ACRE TRACT AND SAID EUGENE C. JUPE FAMILY LIMITED TRACTS TO A STEEL FENCE CORNER POST AT AN INTERIOR CORNER OF SAID EUGENE C. JUPE FAMILY LIMITED TRACTS, FOR THE MOST SOUTHERLY NORTHWEST CORNER OF THE HEREIN DESCRIBED TRACT; THENCE ALONG A BARBED WIRE FENCE WITH THE COMMON LINES OF SAID 9.45 ACRE TRACT AND SAID EUGENE C. JUPE FAMILY LIMITED TRACTS, NORTH 89 DEG 54' 00" EAST 467.00 FEET TO A STEEL FENCE CORNER POST FOR AN INTERIOR CORNER OF THE HEREIN DESCRIBED TRACT AND NORTH 00 DEG 40' 00" WEST 467.00 FEET TO A STEEL FENCE CORNER POST TO A CORNER OF SAID EUGENE C. JUPE FAMILY LIMITED TRACTS, FOR THE MOST NORTHERLYNORTHWESTCORNEROF THE HEREIN DESCRIBEDTRACT; THENCE SOUTH 89 DEG 54' 00" EAST 467.00 FEET ALONG A BARBED WIRE FENCE WITH THE NORTHERNMOST NORTH LINE OF SAID 9.45 ACRE TRACT TO A STEEL FENCE CORNER POST ON THE WEST LINE OF A 52.01 ACRE TRACT AND A 7.70 ACRE TRACT AS RECORDED IN VOLUME 303, PAGE 283, OFFICIAL PUBLIC RECORDS OF ATASCOSA COUNTY, TEXAS, FOR THE NORTHEAST CORNER OF THE HEREIN DESCRIBED TRACT; i THENCE SOUTH 00 DEG 40' 00" EAST 432.18 FEET ALONG A WIRE FENCE WITH THE COMMON LINE OF SAID 9.45 ACRE TRACT, AND SAID 52.01 ACRE TRACT AND SAID 7.70 ACRE TRACT TO A 1/2" STEEL ROD FOUND AT THE NORTH CORNER OF SAID REMAINING PORTION OF 106.23 ACRE TRACT, FOR THE MOST NORTHERLY, SOUTHEASTCORNEROF THE HEREIN DESCRIBEDTRACT; THENCE ALONG A BARBED WIRE FENCE WITH THE COMMON LINES OF SAJD 9.45 ACRE TRACT AND SAJD REMAINING PORTION OF 106.23 ACRE TRACT, SOUTH 89 DEG 54' 00" WEST 415.69 FEET TO A 1/2" STEEL ROD FOUND AT THE NORTHWEST CORNER OF SAJD REMAINING PORTION OF 106.23 ACRE TRACT, FOR AN INTERIOR CORNER OF THE HEREIN DESCRIBED TRACT AND SOUTH 00 DEG 28' 41" WEST 440.20 FEET TO THE POINT OF BEGINNING AND CONTAINrNG 9.45 ACRES OR 411,771 SQUARE FEET, MORE OR LESS. Reported Address: 1501 OLIVE STREET, JOURDANTON, TX 78026 MORTGAGE SERVICING INFORMATION: TheMortgage Servicer, it not the Current Mortgagee, is representing the Current Mortgagee pursuant to a Mortgage Servicing Agreement. Current Mortgagee: MLB SUB I, LLC Mortgage Servicer: BSI Financial Services, Inc. Current Beneficiary: MLB SUB I, LLC Mortgage Servicer Address: 7505 Irvine Center Drive, Irvine, CA 92618 SALE INFORMATION Date of Sale Tuesday, the 6th day of January, 2015 Time of Sale 12:00PM or within three hours thereafter. Place of Sale AT THE WEST PORCH TO THE ATASCOSA COUNTY COURTHOUSE in TXNOS Pg. 2 Matter: 9408-0016; 2146939188 Atascosa County, Texas, or, if the preceeding area is no longer the designated area, at the area most recently designated by the Atascosa County Commissioner's Court. Substitute Trustee(s): Troy Martin or Alexis Martin or Cassie Martin or Terri Martin or Melody Speer, Cristina Camarata, Sammy Hooda, Michael Burns, Alexander Wolfe, Suzanne Suarez or Adam Womack, any to act Substitute Trustee Address: 14841 Dallas Parkway, Suite 425, Dallas, TX 75254 WHEREAS, the above-named Grantor previously conveyed the above described property in trust to secure payment of the Note set forth in the above-described Deed of Trust; and WHEREAS, a default under the Note and Deed of Trust was declared; such default was reported to not have been cured; and all sums secured by such Deed of Trust were declared to be immediately due and payable; and WHEREAS, the original Trustee and any previously appointed Substitute Trustee has been removed and Troy Martin or Alexis Martin or Cassie Martin or Terri Martin or Melody Speer, Cristina Camarata, Sammy Hooda, Michael Bums, Alexander Wolfe, Suzanne Suarez or Adam Womack, any to act, have been appointed as Substitute Trustees and requested to sell the Property to satisfy the indebtedness; and WHEREAS, the undersigned law firm has been requested to provide these notices on behalf of the Current Mortgagee, Mortgage Servicer and Substitute Trustees; NOW, THEREFORE, NOTICE IS HEREBY GIVEN of the foregoing matters and that: 1. The maturity of the Note has been accelerated and all sums secured by the Deed of Trust have been declared to be immediately due and payable. 2. Troy Martin or AlexisMartin or CassieMartin or Terri Martin or Melody Speer,Cristina Camarata, Sammy Hooda, Michael Bums, Alexander Wolfe, Suzanne Suarez or Adam Womack, any to act, as Substitute Trustee will sell the Property to the highest bidder for cash on the date, at the place, and no earlier than the time set forth above in the Sale Information section of this notice. The sale will begin within three hours after that time. 3. This sale shall be subject to any legal impediments to the sale of the Property and to any exceptions referenced in the Deed of Trust or appearing of recordto the extentthe same-are still in effectand shall not cover any property that has been released from the lien of the Deed of Trust. 4. No warranties, express or implied, including but not limited to the implied warranties of merchantability and fitness for a particular purpose shall be conveyed at thesale, save andexcept the Grantor's warranties specifically authorized by the Grantor in the Deed of Trust. The property shall be offered "AS-IS", purchasers willbuy the property "atthepurchaser's own risk" and "athisperil", and norepresentation is made concerning thequality or nature of titleto be acquired. Purchasers will receive whatever interest Grantor andGrantor's assigns have in the property, subject to any liens or interests ofany kind that may survive thesale. Interested persons are encouraged to consult counsel of theirchoice priorto participating in the saleof the property. Very truly yours, Buckley Madole, P.C. TXNOS Pg:3 Matter: 9408-0016; 2146939188 June 2,2015 To: SN SERVICING CORPORATION 323 5th STREET EUREKA CA 95501 FROM: Maryann Castro 1501 Olive Jourdanton Texas 78026 Re: New Loan Number 0000261440 Old Loan Number 44675 Collateral 1501 OLIVE STREET, JOURDANTON TEXAS 78026 Dear: SIR/ MAM NOTICE OF DISPUTE The following problem have occurred in reference to this property you purchased below property value and the two Servicers Wells Fargo Home Mortgage, BSI Financial TOOK part in Mortgage fraud and this has been reported to the Attorney General Of Texas, and the homeowners principle residence Maryann Castro submitted two request the following were submitted a loan Modification and a harp application her request were not denied nor were they approved she never received a response and had to retain an Attorney in Jan 1,2015 to stop foreclosure .And it was stopped and the Mortgage Servicer BSI FINANCIAL did not offer a modification wanted 45,000 to settle the property value is 125,000 and the land is 54,000 see copy of Certified Appraisal. Maryann Castro was awarded the property 1501 Olive on Oct 30,2013 while Wells Fargo held the note and made many promises saying the Modification was in process when it never was Manuel Castro held the note at that time and Wells Fargo never made any attempt to process the Modification knowing there was a hardship at that time Manuel Castro and Maryann Castro were in process of Divorce and Manuel Castro was to make Mortgage Payments and did not he filed Bankruptcy and did not tell Maryann Castro at that time her name was on the Deed Only see the name of the Borrower it says Manuel Castro. Upon final Divorce Maryann Castro did not know Manuel Castro had not made any Mortgage payments and had the home Mortgage in Bankruptcy Protection and owed a balance there is no final Divorce SN Servicing request Making Home Affordable Decree Filed yet. Upon Oct 30,2013 Wells Fargo sold the Note to BSI Financial and this Account was in Active Bankruptcy and Arrears were being deducted weekly from Manuel Castro paycheck see bankruptcy statement BSI Financial put the Debt of Arrears in Maryann Castro name and did not have permission did not notify her they received a copy of the Divorce Decree it was to show she was awarded the Home 1501 Olive not the Debt. The fraud that was committed by BSI Financial has been reported to the Attorney General Office and to the Court Of Appeals in San Antonio Texas. Maryann Castro has made many Attempts to Contact BSI Financial to request a loan modification a harp application and sent it via certified mail and nothing was ever processed and this note was in litigation again now a New Servicer SN Servicing purchase this note below appraisal value attempting to collect what the following Banks have sold below cost in Attempt to collect money causing the high balance on this account for failure to process a loan Modification and putting the unpaid debt Manuel Castro did not pay now remember the Loan was in his name through Wells Fargo then BSI Fraudly put the Debt in Maryann Castro name when she didn't sign the Loan Mortgage due to her disability see copy BSI Put the Debt in Maryann Castro name because of the Document a handwritten Statement showing home 1501 Olivewas Awarded to her on Oct 30,2013 Maryann Castro attempt was to process a Making Home Affordable Modification or Harp Due to Divorce Medical Job Loss. Instead the BSI Servicer applied the Debt in Maryann Castro name when she didn't sign the Home Mortgage loan on this Account when it was Granted and that is Fraud it has been reported to the Better Business Bureau and Attorney General of Texas And she has also Retained Attorney Matthew Obremier of San Antonio Now before it goes any further Maryann Castro is sending again request of A Modification Making Home Affordable (MHA) This was a Fannie Mae account when Wells Fargo granted the Loan a fixed rate and the payments were 1789.00 that is too high Maryann Castro needs the Servicer to process a Modification at 2.4% interest a 30 or even 40 year note and eliminate the high overcharged fees that were applied prior to the new purchaser SN Servicing Corporation accepted not knowing the Actual truth of the account purchase below the value and expect to collect not knowing the Actual facts and lower the house payment at 867.69 monthly. The Servicer Wells Fargo BSI AND prior Owner Manuel G. Castro JR. did not pay the property taxes 2013 and did not insure the home Mortgage property Maryann Castro when she retained the property did not know this and has kept up with Making Sure the Collateral has Home Owners insurance see Policy and taxes are being paid see Balance 2013 were in default and the tax collector wanted to enforce and order and Maryann Castro stopped it by payingthe past due balance Monthly there is still a balance of 725.00 see copy of Tax statement. A copy of this Letter is going to the Following persons Appeals Court in San Antonio Texas Attorney Matthew Obremier Credit Bureau Attorney General of Texas Maryann Castro is seeking a Making Home Affordable Modification Home Affordable Unemployment Programs SN Servicing request Making Home Affordable Home Affordable Foreclosures Alternative, Harp Application due to Divorce, Medical, Job Loss. Affordable Mortgage Payments Relief 1501 Olive is Maryann Castro primary residence when she retained ownership through Divorce she did not know the status of the Account the prior owner had it and had defaulted. Please assist in processing her Request to avoid anymore unneeded unwanted overcharge fees and Attorney fees as she was never provided the Service she applied for to making the Home Affordable. Respectfully Maryann Castro Copy of letter sent Attorney Matthew Obermeier, Appeals Court Of San Antonio Matthew Obermeier 14255 Blanco Rd San Antonio Texas 78216 210-296-5828 Ho SN Servicing request Making Home Affordable a Complete items 1.2, and 3. Also complete item 4 if Restricted Delivery isdesired. mPrint your name and address on the reverse so that we can returnthe card to you. a Attach this card tothe back of themailpiece, oron the front if space permits. raddfeidfffe^tfr^iteml^ •''W ,1. Article Addressed to: ^ nter delivery address below: If YES, enter O N/ Shi S"€ruiClI'V'V 2Q15 3. Service Type D Certified Mail® • Priority Mail Express™ • Return Receipt forMerchandise Q560! O Registered • Insured Mail • Collect on Delivery 4. Restricted Delivery? (Extra Fee) • Yes 2. Article Number (Transfer from service label 7D14 34^0 DDDD ^237 135b [ PS Form 3811, July 2013 Domestic Return Receipt us Complete items1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. Printyour name and address on the reverse so that we can return the card to you. Attachthis card to the back of the mailpiece, or on the front if space permits. ' D. Is delivery address different from item 1? • Yes 1. Article Addressed 5bCU to: l\J. u If YES, enter delivery address below: d No 11 r f^ic ->Md' ^1 Cp.uH ,^OZ.to^W 3. Service Type • Certified Mail® • Priority Mail Express™ E>A Wo nKDuOytf Ufr • Registered • Insured Mail • Return Receipt for Merchandise • Collect onDelivery ' '*& no?n. 4. Restricted Delivery? (Extra Fee) • Yes 2. Article Number (Transfer from service label) 7014 34=10 DDDD ^£3?" 13b3 PS Form 3811, July 2013 Domestic Return Receipt BUCKLEY • MADOLE Buckley Madole, P.C. 14841 Dallas Parkway, Suite 425 Dallas, TX 75254 Main: (972)643-6600 Fax: (972)643-6699 LEGAL PRECEDENT IS NOT CLEAR AS TO WHETHER THE SENDING OF THIS LETTER MAKES US A DEBT COLLECTOR. TO THE EXTENT IT DOES, PLEASE BE ADVISED THAT THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WHX BE USED FOR THAT PURPOSE. HOWEVER, W YOU ARE IN BANKRUPTCY OR HAVE BEEN DISCHARGED IN BANKRUPTCY, THIS LETTER IS FOR INFORMATIONAL PURPOSES ONLY AND IS NOT INTENDED AS AN ATTEMPT TO COLLECT A DEBT OR AS AN ACT TO COLLECT, ASSESS, OR RECOVER ALL OR ANY PORTION OF THE DEBT FROM YOU PERSONALLY. December 2,2014 MARY CASTRO 1501 OLIVE STREET JOURDANTON, TX 78026 Re: Loan No.: 44675 Property: 1501 OLIVE STREET, JOURDANTON, TX 78026 FAm DEBT COLLECTION PRACTICES ACT NOTD7ICATION We represent BSI Financial Services, Inc., whose address is 7505 Irvine Center Drive, Irvine, CA 92618 which, ifitis not the Current Mortgagee, is acting as the Mortgage Servicer and representing the Current Mortgagee pursuant to a Mortgage Servicing Agreement concerning the Note and Deed of Trust which are associated with the above referenced ioan number. Ourfirm has beenrequested to pursueforeclosure processing in accordance with the terms of the Note and Deed of Trust and applicable law. 1. According to the information provided to usbyourclient, thetotal amount required to cure thedefault under thenote and deed oftrust through December 15, 2014 is$79,019.30 and the total amount required topayoff the debt through November 30,2014 is $275,251.54. 2. Because ofpayment installments that accrue monthly and other charges that may vary from day to day, the total amount required to cure the default may be greater on the day thatyou choose to pay. Likewise, because of interest and/or other charges that may vary from day to day, thetotal amount required topayoffthedebt may begreater onthe day that you choose topay. Hence, should you choose to pay either ofthe amounts shown above, anadjustment may be necessary after your check is received in which event we will notify you before the check is deposited for collection. For further information, write our firm at Buckley Madole, P.C, Attn: Foreclosure Department, 14841 Dallas Parkway, Suite 425, Dallas, TX 75254 or call us at (972) 643-6600 . 3. You have thirty days after you receive this letter to dispute the validity of the debt or any part of it. If you do not dispute it within that period, our firm will presumethat it is valid. 4. Ifyou notify our firm inwriting within the thirty-day period that the debt, orany portion thereof, is disputed, our firm will obtain verification ofthe debt or a copy ofajudgment against you and a copy of such verification orjudgment will be mailed to you by our firm. If you require further information,please let us hear from you. Very truly yours, Buckley Madole, P.C. ACCEPTEC 041400785CV FOURTH COURT OF APPEAL SAN ANTONIO, TEXAS 1/9/2015 3:02:21 PM KEITH HOTTLl CLERK COURT OF APPEALS NO. 04-14-00785-CV TRIAL COURT CASE NO. 2011 CI 15957 IN THE MATTER OF § IN THE DISTWCT4G<&#fOFAPPEALS THE MARRIAGE OF § SAN ANTONIO, TEXAS § 01/9/2015 3:02:21 PM MANUEL G. CASTRO § 45th JUDICIAL DISTUaOTE. HOTTLE AND § Clerk MARY ANN CASTRO § BEXAR COUNTY, TEXAS RESPONSE TO APPELLANT'S AFFIDAVIT OF INDIGENCY This Response is brought by Appellee, MANUEL G. CASTRO, by and through his attorney, JOSEPH P. APPELT, who shows in support thereof: 1. On or about December 29,2014 Appellant filed certain documents, including an Affidavit ofIndigency in this matter; 2. Appellee contests thevalidity of saidaffidavit based on several facts that have come to light during the course of thematter in District Court; 3. First, Appellant asserts in hersworn affidavit thatheronly source of income is herSocial Security disability check in the amount of $788.00 permonth. This is a false statement forthe following reasons: a. Appellant, Mary Ann Castro, has a catering business "Catering by Mary Ann" as evidenced by the advertisement attached hereto as exhibit "A" b. Appellant has stated in court that she makes "$15 an hour," evidenced by her statement on line 15 of page7 of the certified transcript attached hereto as Exhibit "B" 4. In addition, Appellee further objects tothe validity ofAppellant's affidavit inthat she is currently the owner ofa 2013 Chevrolet Cruz automobile; evidencing her income isgreater than only the $788.00 monthly Social Security check she swore to inthe said affidavit; . 5. Also, Appellant files heraffidavit in support ofother filings indicating she does not have thefinancial resources to payhercosts or hire an attorney. Appellant has made this same j assertions throughout the case at the District Court level yet she has retained the following attorneys in conjunction with her case: a. Edward Piker J b. Rebecca C. Martinez (now a Justice on the 4,h Court ofAppeals) |..i."'P0 > ROOM 101 >P. 4100 S NEW BRAUNFELS ^ ^S^TX &/L/^y ^\ We will process your application for Supplemental Security Income as quickly as possible. You should hear from us within J PO days. If you do not hear from us by then, please get in touch with us. We will let you know if we need more information to decide if you are eligible for SSI payments. In the meantime, if you move or change your mailing address, you--or someone for you-- should report the change to the office shown abovlT. Also, you (or someone for you) must let us know if you are admitted to a hospital or other medical facility. You could lose some SSI payments if you do not let us know right away. Always give your Social Security"" number when writing" or telephoning-about "your" claim. If you have any questions about your claim, we will be glad to help you. MARYANN CASTRO _. ~ — 919 SUTTON APT 22 SAN ANTONIO, TX 78228 !>*#" ?• Your New Benefit Amount 15o4494 BENEFICIARY'S NAME: MARYANN CASTRO .Your Social Seciirilybenefits will iacrease;by 1J:percent In2015 because ofarise mthecost of li%isg. Ybu can ase this 1^ rent, or energy assistance; bank loans; or for other business. Keep this letter with your important financial records. How Much Will I Get And When? 8Your monthly amount (before deductions) is $1,148.90, • The amount we deduct for Medicare medical insurance is $104.90. z3S ±HOa^h Fndaj Recorded information and services a^^ «^»sx~*.*-- =. .- -j ^busiest early in the week, early in the month, as well as during the week between Christmas and NewYear's Day; it is best to call at other times. Ifyou are deaforhard ofhearmg, caM our TTY number 1-800-325*0778. Ifyou are outside the United States, you can comaet_anyX ._- Embassy or consulate office. Please have your Social Security claim number ava^wJ.^l Mining Group Inc. Advice Routing: Pay Grpup: SUM-Hourly Cra; Opportunity Employer Dept: 14965 - San Miguel Labor Pay Begin Date: 04/01/2013 :31096 Sub Payroll: 3 Pay End Date: 04/07/2013 fE 68131 402/342-2052 Pay Basis: Hourly ruadalup« Castro Jr LAST JOB WORKED: >TAX DATA:, Federal :kory Shadow Empl #: 00000 Marital Status: Marriec fTX 78112 Job#: 14965 Allowances: 0 Location: San Miguel Labor Addl. Pet.: 247763 Addl. Amt.: liiM?i^i:i;iai^6Ja^ta Current YTD n Rate Hours Earnings Hours Earnings Description^ 20.710000 40.00 828.41 52350 10324.70 Fed Wlthholdng - Time and One H 31.065000 18.00 559.17 147.00 456238 Fed MED/EE ay 23.00 47139 Fed OASDI/EE Off 4350 900.90 n Non-Taxable 324.83 58.00 138758 737.00 17,08420 Total: s^ijiiiiii^ W^m^mmM^im n Current YTD Description Current YTD Description lsurance 5459 77150 Employee Supplemental Lif 5.10 7650 Medical Insurance urance 527 78.14 Accident Death & Dismbr - 030 450 Vision Insurance Depend AD & D - KieChoice 0.18 2.70 Group Term Life Insuram Clothing 4.15 6025 Group Term Life Insuram Garnishment - Bankruptcy 184.62 2,76930 Disability Insurance 59.86 849.64 I Total: 19435 251325 L* Taxable" ~~~~" 138758 1329.00 259.91 25421 17,08420 15,928.86 E: Advice #53850 Total: * 1 2 REPORTER'S RECORD 3 VOLUME 1 OF 1 VOLUME 4 TRIAL COURT CAUSE NO. 2011-CI-15957 5 MANUEL G. CASTRO ) IN THE DISTRICT COURT ) 6 VS. ) 45TH JUDICIAL DISTRICT ) 7 MARY A. CASTRO ) BEXAR COUNTY, TEXAS 8 9 10 11 HEARING 12 DECEMBER 29, 2014 13 14 On the 29th day of December 2014, the following 15 proceedings came on to be heard in the above-entitled and 16 numbered cause before the HONORABLE BARBARA NELLERMOE, Judge 17 Presiding, held in 45th District Court, Sah Antonio, Bexar 18 County, Texas: 19 Proceedings reported by machine shorthand. 20 21 22 i -.r 23 24 25 JUDITH A. STEWART, C.S.R. 45TH DISTRICT COURT / interest, and claim in and to that property: H-l. All household furniture, furnishings, fixtures, goods* art objects, collectibles, appliances, and equipment in the possession of the husband or subject to his sole control. H-2. All clothing, jewelry, and other personal effects in the possession of the husband or subject to his sole control, H-3. All sums of cash in the possession of the husband or subject to his sole control, including funds on deposit, together with accrued but unpaid interest, in banks, savings institutions, or other financial institutions, which accounts stand in the husband's sole name or from which the husband has the sole right to withdraw funds or which are subject to the husband's sole control. H-4. All sums, whether matured or unmatured, accrued or unaccrued, vested or otherwise, together with all increases thereof, the proceeds therefrom, and any other rights related to any profit-sharing plan, retirement plan, Keogh plan, pensionjlari, employee stock — . f option plan, 401 (k) plan, employee savings plan, accrued unpaid bonuses,, disability plan, or f — O ^iE. do ^o^^^^g-4^^ other benefits existing by reason ofthe riusbandVpast, present, or future employme&tJ /\ qa Lp^ /V1 0 rjr H-5. All individual retirement accounts, simplified employee pensions, annuities, and'p- J variable annuity life insurance benefits in the husband's name. H-6. The 1999 Subaru motor vehicle, together with all prepaid insurance, keys, mid title documents. ~^ U^^^&Pt ^Jjfch ft^c/o^/^ , ED AND DECREED that the wife, MARY ANN CASTRO, is awarded the •/-• s •—~ "V 'tnd separate property, anc| the husband isdivested ofall right, title, interest, Jt property: same date, butsigned on £Xco l>*« ^f '3- list " s juVV , u " fi" V "^'"a^xN' I *^K 1 * t.. *% r ^ f h1^s://mail.googlexom/Jscs/mail-sMic/Jjs/k=gmail.main.en.HGrFWflRUk.O/m==m 1/2/2014 GREEN TREE SERVICING LLC 1-800-643-0202 345 SAINT PETER STREET L1000 99C SAINT PAUL, MN 55102 + 0533173 000021017 01GT1C 0137107 D12S201S MARY ANN CASTRO PO BOX 495 • PLEASANTON TX 78064-0495 !'i'»iilli>l{i>ll'iilr'li>illllgll!'ll'Pi|ililll"ii !•" •••!•*_ " J. 1 A i rI i % m I fl SC0104-000 I1 . » n.1 AI 'It it*' Instructions for Debtor You received this form because a Federal Government agency or an applicable Box 4. Shows a description of the debt. If box 7 is completed, box 4 also financial entity (a creditor) has discharged (canceled or forgiven) a debt you shows a description of the property. owed, or because an identifiable event has occurred that either is or Is deemed to be a discharge of a debt of S600 or more. If a creditor has discharged a debt Box 5. Shows whether you were personally liable for repayment of the debt you owed, you are required to include the discharged amount in your income, when the debt was created or, if modified, at the time of the last modification. even if it is less than S600, on the "Other income* line of your Form 1040. See Pub. 4681 for reporting instructions. However, you may not have to include all of the canceled debt in your income. There are exceptions and exclusions, such as bankruptcy and insolvency. See Box 6. Shows the reason your creditor has filed this form. The codes in this Pub. 4681, available at IRS.gov, for more details. If an identifiable event has box are described in more detail in Pub. 4681. A—Bankruptcy; B—Other occurred but the debt has not actually been discharged, then include any judicial debt relief; C—Statute of limitations or expiration of deficiency period; discharged debt in your income in the year that it is actually discharged, unless D—Foreclosure election; E—Debt relief from probate or similar proceeding; an exception or exclusion applies to you in that year. F—By agreement; G—Decision or policy to discontinue collection; H—Expiration of nonpayment testing period; or I—Other actual discharge Debtor's identification number. For your protection, this form may show only before identifiable event. the last four digits of your social security number (SSN), individual taxpayer identification number (ITIN), or adoption taxpayer identification number (ATIN). However, the creditor has reported your complete identification number to the Box 7. If, in the same calendar year, a foreclosure or abandonment of property IRS and, where applicable, to state and/or local governments. occurred in connection with the cancellation of the debt, the fair market value (FMV) of the property will be shown, or you will receive a separate Form Account number. May show an account or other unique number the creditor 1099-A. Generally, the gross foreclosure bid price is considered to be the FMV. assigned to distinguish your account. For an abandonment or voluntary conveyance in lieu of foreclosure, the FMV is generally the appraised value of the property. You may have income or loss Box 1. Shows the date the earliest identifiable event occurred or, at the because of the acquisition or abandonment. See Pub. 4681 for information creditor's discretion, the date of an actual discharge that occurred before an about foreclosures and abandonments. If the property was your main home, identifiable event. See the code in box 6. see Pub. 523 to figure any taxable gain or ordinary income. Box 2. Shows the amount of debt either actually or deemed discharged. Note. Future developments. For the latest information about developments related If you do not agree with the amount, contact your creditor. to Form 1099-C and its instructions, such as legislation enacted after they were published, go to www.irs.gov/form1099c. Box 3. Shows interest if included in the debt reported in box 2. See Pub. 4681 to see if vou must include the interest in gross income. • CORRECTED (if checked) CREDITOR'S name, street address, city or town, state or province, country, ZIP or OMB No. 1545-1424 foreign postal code, and telephone no. GREEN TREE SERVICING LLC Cancellation 345 SAINT PETER STREET L1000 99C SAINT PAUL, MN 55102 »®14 of Debt 1-800-643-0202 Form 1099-C CREDITOR'S Federal identification number DEBTOR'S identification number 1 Date of identifiable event 2 Amount of debt discharged XX-XXXXXXX XXX-XX-5895 02/04/2014 11,792.97 Copy B $ For Debtor DEBTOR'S name, street address (including apt. no.l, city or town, state or province, 3 Interest if included in box 2 4J Debt description This is important tax country, and ZIP or foreign postal code information and is being furnished to the Internal Mortgage Loan Revenue Service. If you $ are required to file a 5 If checked, the debtor was personally liable for repayment of the return, a negligence MARY ANN CASTRO penalty or other PO BOX 495 debt *• fXl sanction may be PLEASANTON TX 78064-0495 imposed on you if taxable income results 6 Identifiable event code 7 Fair market value of property from this transaction A and the IRS determines that it has not been Account number (see instructions) reported. 27502923 Form 1099-C (Keep for your records.] www.irs.gov/form1099c Department of the Treasury - Internal Revenue Service Green Tree Servicing LLC QCQQt\ VtQ& Document Custody - T313 7360 S. Kyrene Rd. Tcmpe,AZ 85283 1-888-315-8733 Fax 1-888-221-7381 GTServiflflg.CQin February 13,2014 HIGIER, ALLEN AND LAUTCN ATTN:RICRABD MCKJNNEY 5057 KELLER SPRINGS RD.,STE600 ADDISON, TX 75001 RE: Account Number 27502923*; Dear StR OR MADAM; Our records indicate the above-referenced account with Green Tree ServicingLLC* ("Green .Tree") has been settled infill. Enclosed are certain original documents you should retain for your records in connection with your account. Ifyou have any questions regarding this account, please contact our Document Custody department at 1-888-315-8733 ext. 33705. Sincerely, Green Tree •Green Tree Servicing LLC and related entities, including, for certain loans, in Alabama, Green Tree-AL LLC; in Minnesota, Green Tree Loan Company; and in Pennsylvania, Green Tree Consumer Discount Company. Account S«tted-iii-Full-Borrower Ddcs 03-0M0 LTR-551 Statement of Account NOTICE: This is a statement of Taxes Due as of 06/01/2015 12:26:41PM based upon the tax records of the tax office. ATASCOSA COUNTY TAX OFFICE , . • - vr'Vs-;) ;:Property Information 1001 OAK STREET Property ID: 65922 'Geo ID: 00769-00-000-000505 JOURDANTON, TX 78026 Legal Acres: 0.0000 Legal Desc: IMPROVEMENT ONLY, LABEL #TEX0561908, LOC ON : PID 58181 Situs: 1965PATTON RD , DBA: Exemptions; . \_. Owner ID: 145456 Ownership: 100.00% CASTRO MANUEL & MARY ANN Value Information % MICHAEL & MISTY HERNANDEZ Improvement HS: 19,910 7815 E 3RD ST Improvement NHS: 0 Land HS: 0 SOMERSET, TX 78069 Land NHS: 0 Productivity Market: 0 .Productivity Use: 0 Assessed Value 19,910 Entity. Description -..•'. '•'V '' '"' • : Pet. sExCode'ji-frJv Description'??- FMLR ' FARM TO MARKET ROAD 100.00% GAT ATASCOSA COUNTY 100.00% SPO POTEETISD 100.00% WEV EVERGREEN WATER DIST 100.00% Unpaid Bills Summary Entity Year Statement ID Tax Rate Type 'v-TaxDue Disc/P&l Attorney Feesn. Total Due FMLR 2013 53837 0.076000 L ' 9.94 2.88 1.92 14.74 GAT 2013 53837 0.340600 L 44.55 12.91 8.62 66.08 SPO 2013 53837 1.419000 L 185.59 53.82 35.91 275.32 WEV 2013 53837 0.006000 L 0.78 0.22 0.15 1.15 Total for Year 2013 240.86 69.83 46.60 357.29 Total For All Years 240.86 69.83 46.60 357.29 Total Due if Paid By 06/30/2015 357.29 Paid Refunds Summary , , ';: Entity' Year' Statement ID < "* < Date Refunded; ^Refund Amount Raid Total For Year 2013 0.00 FMLR 2009 6439 01/07/2010 0.70 GAT 2009 6439 01/07/2010 3.11 SPO 2009 6439 01/07/2010 6.13 WEV 2009 6439 01/07/2010 0.06 Total For Year 2009 10.00 Total Refunds Paid 10.00 *** End of Statement "* NOTICE: This document is not a tax certificate and does not absolve a Taxpayer from tax liability in any way. If this document is found to be Page 1 in error, it may be corrected by the Collection Officelisted above. Responsibility to pay the remaining taxes rests entirely with the Taxpayer, True Automation. Inc. as outlined in the Texas Property Tax Code. J&Jr.JPG Page 1 of1 i)fV'% . ' .I**"fa. 1* V «Jw f <* I I I. i» II v^v f£ https://mail.google.com/J'scs/mail-s^^ 1/2/2014 To; Michael and Misty Hernandez 7815 E 3RD St Somerset Texas 78069 From; Maryann Castro 1501 Olive Jourdanton Texas 78026 Enclosed is the contract you signed and attempted fraud by not communicating with Maryann Castro who did not surrender her interest. You owe a-te fees, interest, taxes and have not made one payment on or about July 2011 and conspired to own a asset that you have not paid off the agreement signed by you see copy. Maryann Castro will accept a reasonable offer in the amount of 15,000 the balance owed to Maryann Castro is 2011 Aug,St,Oct,Nov,Dec with late fee =2750 2012 Jan-Dec No payments and late fee added 6600 rs 201.3 Jan-Dec No Payments and late fee added 6600 2014 Jan- Dec No payments and late fee added 6600 2015 no payment made or taxes paid and late fee 3300 Unpaid taxes 357-29 The.agreement is void and right to repossession until payment is made in full the agreement is valid and it was not given to you the 95 fleetwood Itried working it out with you and you threatened me. I am in my right to reposes and you agreed to pay and pay the terms ignoring this will not make it go away. Total due-26,207.29-7000 you paid Greentree Servicer the title is not released to you due to non-payment total due as of 6/1/2015 is 19,207.29 Maryann Castro will settle for 15,000. Copy sent on 6/1/2015 this is a legal matter and needs to be settled the servicer was paid and you disregarded the contract with the attempt to steal an asset not awarded to you and debt not paid to Maryann Castro see contract Manuel Castro surrendered his interest and the debt is to be paid to Maryann Castro you have 30 days to respond and payVrepossession will take place by law I am in the right the contract was never paid in full. Your Attorney did not clear you from paying me the outstanding balance. Please remit payment or surrender the 95 fleetwood you signed you will return if you do not pay and you have not attempted any communication or payment. > Respectfully Maryann Castro 1501 Olive Jourdanton Texas 78026 Date 6/1/2015 ff /A NOTICE: This is a statement of Taxes Due as of 06/01/2015 12:26:41PM based upon the tax records of the tax office. ATASCOSA COUNTY TAX OFFICE Property Information 1,001 OAK STREET Property ID: 65922 Geo ID: 00769-00-000-000505 JOURDANTON, TX 78026 Legal Acres: 0.0000 Legal Desc: IMPROVEMENT ONLY, LABEL #TEX056'1908, LOC ON PID 58181 Situs: 1965PATTON RD , DBA: Exemptions: i Owner ID: 145456 Ownership: 100.00% CASTRO MANUEL & MARYANN Value Information % MICHAEL & MISTY HERNANDEZ Improvement HS: 19,910 7815 E 3RD ST • Improvement NHS: 0 Land HS: 0 SOMERSET, TX 78069 Land NHS: 0 Productivity Market: 0 Productivity Use: 0 Assessed Value 19,910 Entity Description Pet. Ex Code Description FMLR FARM TO MARKET ROAD 100.00% GAT ATASCOSA COUNTY 100.00% SPO POTEET ISD 100.00% WEV EVERGREEN WATER DIST 100.00% Unpaid Bills Summary Entity Year Statement ID Tax Rate Type Tax Due Disc/P&l Attorney Fees Total Due FMLR 2013 53837 0.076000 L 9.94 2.88 1.92 14.74 GAT 2013 53837 0.340600 L 44.55 12.91 8.62 66.08 SPO 2013 53837 1.419000 L 185.59 53.82 35.91 275.32 WEV 2013 53837 0.006000 L 0.78 0.22 on 5 1.15 Total for Year 2013 240.86 69.83 46.60 357.29 Total For Ail Years 240.86 69.83 46.60 357.29 Total Due if Paid By 06/30/2015 357.29 Paid Refunds Summary Entity Year Statement ID Date Refunded Refund Amount Paid Total For Year 2013 0.00 FMLR 2009 6439 01/07/2010 0.70 GAT 2009 6439 01/07/2010 3.11 SPO 2009 6439 01/07/2010 6.13 WEV 2009 6439 01/07/2010 0.06 Total For Year 2009 10.00 Total Refunds Paid 10.00 *** End of Statement *** NOTICE: This document is not a tax certificate and does not absolve a Taxpayer from tax liability in any way. If this document is found to be Page 1 in error, it may be corrected by the Collection Office listed above. Responsibility to pay the remaining taices rests entirely with the Taxpayer, Tfu« Automation, Inc. as outlined in the Texas Property Tax Code. •* i fS^T -• > *'t f \"-; 'f- ^ify "t n* ",**« -''"'" -* it 5? si1 (. f! ». -All James E. Dickson Jr., M.D. Diplomate American Board of Psychiatry and Neurology 14815 San Pedro Ave. San Antonio, Texas 78232 Phone: (210)494-1991 Fax: (210)494-7575 January 31, 2013 To Whom it May Concern: This is to confirm that Mary Ann Castro has been a patient of mine beginning with her initial evaluation with me on 3/2/01. She has past psychiatric diagnoses of Major Depression, and Panic Disorder. In addition she also exhibited some symptoms consistent with Attention Deficit Disorder. She was last seen by me on .12/21/11. Sincerely, James Dickson Jr., M.D. Silvester Foot Clinic 409 N. Bryant Pleasanton, TX 78064 (830)569- 3338 FAX (830)569- 6833 Patient: CASTRO, MARYANN, DOB: 09/23/1965, Age: 49 years, Female Acct #: 4320 CHART SUMMARY Name: CASTRO, MARYANN Acct# 4320 1501 OLIVE Date of Birth: 09/23/1965 JOURDANTON, TX Gender: Female 78026 Work Phone: None Home Phone: (830)496-0133 Cell Phone: None Email: Marital Status: Spouse/Partner: Primary Ins: MEDICARE DC TEXAS Secondary Ins: BLUE CROSS BLUE SHIELD Last Plan Note: 06/09/2015 Order bone stimulator and Subtalar joint immobilizing AFO (Arizona). Patient was scheduled for casting of the AFO. The patient was requesting an additional injection but I explained that steroid injections can delay the bone healing that should normally occur and I do not want to do that. I also discussed the possibility of percutaneous surgery which would involve injecting the sinus where the screw was removed with some type of bone morphogenic protein or osteogenic gel, and percutaneous screw fixation of the subtalar joint to stabilize the joint. I explained that this may or may not lead to a solid ossification of the subtalar joint but could providers with significant relief. Vitals: Date 06/09/2015 Height 62 inches (157.48 cm) Weight 187 pounds (84.82 kg) BMI 34.19 Current Problems: TRAUMATIC ARTHROPATHY INVOLVING ANKLE AND FOOT (716.17), onset: 05/08/2015, Noted, last assessed: 06/01/2015 UNSPECIFIED SITE OF ANKLE SPRAIN (845.00), onset: 05/08/2015, Noted ANKLE INSTABILITY OTHER JOINT DERANGEMENT NOT ELSEWHERE CLASSIFIED INVOLVING ANKLE AND FOOT (718.87), onset: 05/08/2015, Noted, last assessed: 06/01/2015 PERONEAL TENDON RUPTURE (TRAUMATIC) OTHER ANKLE SPRAIN (845.09), onset: 05/11/2015, Noted, last assessed: 06/01/2015 PERONEAL TENDINITIS OTHER ENTHESOPATHY OF ANKLE AND TARSUS (726.79), onset: 05/11/2015, Noted, last assessed: 06/01/2015 UNSPECIFIED PRURITIC DISORDER (698.9), onset: 05/11/2015 PAIN IN LIMB (729.5), onset: 05/20/2015, Noted, last assessed: 06/09/2015 POSTSURGICAL ARTHRODESIS STATUS (V45.4), onset: 06/01/2015, Noted, last assessed: 06/09/2015 NONUNION OF FRACTURE (733.82), onset: 06/09/2015 Current Medications: metformin 500 mg tablet extended release 24 hr, TK 1 T PO EVERY DAY X 30 Days, Start Date: 11/21/2014 omeprazole 20 mg capsule.delayed release(DR/EC), TK 1 C PO QD X 30 Days, Start Date: 11/21/2014 Ambien (Zolpidem) 5 mg tablet Take 1 tablet as directed, Take one about 1 hour pre op. Bring the medication to the procedure and repeat if needed, Disp. 4 NR, Start Date: 05/11/2015 Printed by Marilee Silvester on 06/16/2015, Page 1 of 2 CPTonr/0 2014 American Madltal Association. AllRights RasarvaO. Silvester Foot Clinic 409 N. Bryant Pleasanton, TX 78064 (830)569- 3338 FAX (830)569- 6833 Patient: CASTRO, MARYANN, DOB: 09/23/1965, Age: 49 years, Female Acct #: 4320 metoprolol succinate 25 mg tablet extended release 24 hr, TK 1 T PO QD X 30 Days, Start Date: 12/01/2014 hydrochlorothiazide 25 mg tablet, TK 1 T PO EVER DAY X 30 Days, Start Date: 11/21/2014 levothyroxine 150 meg tablet, TK 1 T PO EVERY DAY FOR 30 DAYS X 30 Days, Start Date: 11/21/2014 Current Allergies: No Known Drug Allergies Medical History Thyroid dysfunction (Yes). Hypertension (Yes). Diabetes (Yes). Arthritis (Yes). Cancer- breast, tumors. Surgical History Ankle surgery - Right. hysterectomy. mastecomy. Thyroid. Tumor on ovary. Throat cyst. Family History Diabetes, Type II - Natural Mother. Cancer - Natural Father - What type of cancer? - Colon; Natural Sister - What type of cancer? - bone. Social History Smoking status: Never smoker (266919005). Smokeless Tobacco Use (No). Illicit/Recreational Drugs (No), alcohol use (No). Alcohol (No). Printed by Marilee Silvester on 06/16/2015, Page 2 of 2 CPT onlyO 2014 AmericanMsdital Association. AU Rights RoServed. Edfinancial Services "PO Box 36014 Knoxville, TN 37930-6014 SERVICES MARY ANN CASTRO Statement Date: 12/12/14 PO BOX MTS Account Number: C872043321 PLEASANTON TX 7fl0t.M-DM^S Account Summary: GROUF» F GROUF> G Loan Type STAFFORD STAFF 3RD Original Principal Amount $ 1,500.00 $ 2,780.00 Lender Name NTHEA NTHEA Current Interest Rate 02.330% 06.800% Current Principal Balance $ 2,076.37 $ 3,375.46 Accrued Interest on next Due Date $ 16.01 $ 12.56 Interest Paid Since Last Statement $ 0.00 $ 0.00 Total PrincipalPaid Through 12/12/14 $ 0.00 $ 0.00 Total Interest Paid Through 12/12/14 $ 0.00 $ 0.00 Total Fees Paid Through 12/12/14 $ 0.00 $ 0.00 Total Amount Paid Through 12/12/14 $ 0.00 $ 0.00 Total PayoffAmount Through 01/02/15 $ 2,099.08 $ 3,401.02 Fees Assessed Since Last Statement: Late Fees $ 0.00 $ 0.00 Non-Sufficient Fund Fees $ 0.00 $ 0.00 Legal Fees $ 0.00 $ 0.00 Collection Fees $ 0.00 $ 0.00 Servicing Fees $ 0.00 $ 0.00 Current Billing Summary: Monthly Payment Amount $ 0.00 $ 0.00 '% A \- .' t Total Past Due $ 0.00 $ 0.00 Outstanding Fees $ 6.70 $ 13.00 Total Amount Due on statement date $ 0.00 $ 0.00 Penalty for Late Payments: Charge ifpayment not received by 10/23/15 10/23/15 Late Fee Amount $ 0.94 $ 1.90 J o ACCOUNT INFORMATION We're preparing information to show how much student loan interest you paid in2014. It will be sent to youbythe endof January inyour billing n statement, ifapplicable. The statement or letter will serve as your official IRSForm 1098-E.You can also log in at www.edfinancial.com startingJanuary12to view yourtax information. SEE REVERSE SIDE FOR IMPORTANT ACCOUNT INFORMATION PLEASE DETACH AND SEND BOTTOM PORTION WITHYOUR PAYMENT Account Number C872043321 NAME ON CHECK IF DIFFERENT FROM STATEMENT: Payment Due Date 01/02/15 Total Due $ 0.00 Sign upat www.edfinancial.com for ourconvenient auto-debit payment option and electronic correspondence. Check this box for change of address. See reverse side. Please writeyour account number on your check or money order. PLEASE DO NOT SEND CASH. Check this box ifyou completed the special payment instructions on the reverse side. Ifa check isrelumed unpaid for insufficient funds, itmay berepresented electronically. Payment Address: MARYANN CASTRO PO BOX 495 I..II.I...II.I..I.I...I.I.LI ll....l.l..l.l.l.l,.l,l PLEASANTON TX 78064-0495 Ill Edfinancial Services Dept. 888055 Knoxville, TN 37995-8055 idssflt^assMaamflssflb a ddddodd i Edfinancial Services PO Box 36014 Knoxville, TN 37930-6014 SERVICES £si!i>i|'lll'»'il''li'l><>i>lillii»il'li>l«>>ll >0385b, UADS?11]! 001 008167 10Z Statement Date: 12/12/14 MARY ANN CASTRO Account Number: C872043321 PO BOX MIS PLEASANTON TX 7aom-DMTS Account Summary: GROUP A GROUP B GROUP C GROUP D GROUP E Loan Type STAFFORD STAFFORD STAFFORD STAFFORD STAFFORD Original Principal Amount $ 2,625.00 $ 4,000.00 $ 3,500.00 $ 4,000.00 $ 875.00 Lender Name NTHEA NTHEA NTHEA NTHEA NTHEA Current Interest Rate 02.330% 02.330% 02.3307 02.3307 02.3307o Current Principal Balance $ 3,152.03 $ 5,674.88 $ 4,102.38 $ 5,693.86 $ 1,025.51 Accrued Interest on next Due Date $ 4.02 $ 43.81 $ 5.23 $ 43.94 $ 1.30 Interest Paid Since Last Statement $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Total Principal Paid Through 12/12/14 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Total Interest Paid Through 12/12/14 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Total Fees Paid Through 12/12/14 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Total Amount Paid Through 12/12/14 $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Total Payoff Amount Through 01/02/15 $ 3,166.39 $ 5,736.92 $ 4,121.08 $ 5,756.08 $ ,030.17 Fees Assessed Since Last Statement: Late Fees $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Non-Sufficient Fund Fees $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Legal Fees $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Collection Fees $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Servicing Fees $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Current Billinq Summary: Monthly Payment Amount $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Total Past Due $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Outstanding Fees $ 10.34 $ 18.23 $ 13.47 $ 18.28 $ 3.36 Total Amount Due on statement date $ 0.00 $ 0.00 $ 0.00 $ 0.00 $ 0.00 Penalty for Late Payments: Charge if payment not received by 10/23/15 10/23/15 10/23/15 10/23/15 10/23/15 Late Fee Amount $ 1.47 $ 2.58 $ 1.91 $ 2.59 $ 0.48 ACCOUNT INFORMATION We're preparing information to show how much student loan interest you paid in 2014. It will be sent to you by the end of January in your billing n statement, if applicable The statement or letter will serve as your official IRS Form 1098-E. fou can also log in at www.edfinancial.com starting January 12 to view your tax information. SEE REVERSE SIDE FOR IMPORTANT ACCOUNT INFORMATION PLEASE DETACH AND SEND BOTTOM PORTION WITH YOUR PAYMENT. Account Number C872043321 NAME ON CHECK IF DIFFERENT FROM STATEMENT: Payment Due Date 01/02/15 Total Due $ 0.00 Sign up at www.edfinancial.com for our convenient auto-debit payment option and electronic correspondence. Check this box for change of address. See reverse side. Please write your account number on your check or money order. PLEASE DO NOT SEND CASH. . _ Check this box if you completed the spedal payment instructions on the reverse side. If a check is returned unpaid for insufficient funds, it may be represented electronically. Payment Address: MARYANN CASTRO PO BOX 495 PLEASANTON TX 78064-0495 I..II.I.mII,I„I,I,„I,I,I„I,II„,.I.I..I I.I..I.Im.mI Edfinancial Services Dept. 888055 Knoxville, TN 37995-8055 iDssfib^assMflBmassflb a odddddd i £?• S>J^> ^f^LINEBARGER GOGGAN BLAIR &SAMPSON, LLP -HpC"~ ATTORNEYS AT LAW ^5 ^ ,}-o<2-S u)»Xc ESTA CORRESPONDENCIA SE TRATA DE SUS IMPUESTOS Y LA POSIB1LIDAD DE UNA DEMANDA ACERCA DE SU PROPIEDAD SI H-124E USTED DESEA ASISTENCIA POR UNA PERSONA QUE HABLA ESPANOL, LLAME USTED A(800)876-6144 YUNA PERSONA LE AYUDARA is>wi, CASTRO MANUEL & MARYANN PO BOX 495 PLEASANTON TX 78064-0495 ili"ililll«iliilll','i"l'illlim'hll'»1il I'lli'»i,'lll RE: Acct. # 17471 CAD#17471 - ABS A01239 J POITEVENT SV-1,9.45 ACRES (see attachedpELINQUENT ACCOUNT STATEMENT) NOTICE OF LEGAL ENFORCEMENT Dear Atascosa County Taxpayer: Our law firm mailed a letter dated July 16, 2014 advising you to pay your property taxes and they still remain unpaid. You must contact our office to address this matter and avoid legal action. We have legal representatives ready to assist you by calling (210) 362-9000. Failing to contact our office or the Atascosa County Tax Office to pay your taxes can result in a lawsuit being filed against you seeking the foreclosure of your property. Once a lawsuit is filed, court costs and fees associated with the lawsuit will be your responsibility. You can avoid legal action and the possibility of foreclosure by contacting our law office or mailing paymenttoday with the enclosed statement to: Atascosa County 1001 Oak St Jourdanton, TX 78026-2849 (830)769-3842 YOU MAY OWE ADDITIONAL TAXES TO ENTITIES NOT SHOWN ON THE ATTACHED STATEMENT. FOR ADDITIONAL INFORMATION, PLEASE CONTACT THE OFFICE OF THE ATASCOSA COUNTY TAX ASSESSOR-COLLECTOR, LORETTA HOLLEY, AT (830) 769-3842. PLEASE DO NOT HESITATE - WE ARE HERE TO HELP YOU. We have been instructed by the Office of the Atascosa County Tax Assessor-Collector to advise you that ifyou are solicited by a lender offering to loan you money to pay your taxes through a tax lien transfer loan, be aware that administrative fees and costs are associated with the tax lien transfer loan. To learn about the options available to you to pay your taxes, contact our law office or the Atascosa County Tax Office. Ifyou believe this statement is in error please WRITE to our law office at 711 Navarro Street, Ste 300, San Antonio, TX 78205 and supplythe ACCOUNT NUMBER alongwith your comments. TEXAS LAW REQUIRES THAT WE NOTIFY YOU THAT IF YOU ARE 65 YEARS OF AGE OR OLDER OR DISABLED, AND YOU OCCUPY THE PROPERTY DESCRIBED IN THIS DOCUMENT AS YOUR RESIDENCE HOMESTEAD, YOU SHOULD CONTACT THE APPRAISAL DISTRICT REGARDING ANY ENTITLEMENT YOU MAY HAVE TO A POSTPONEMENT IN THE PAYMENT OF THESE TAXES. Sincerely, Ronald E. Rocha Attorney at Law H-163J ESTA CORRESPONDENCIA SE TRATA DE SUS IMPUESTOS Y LA POSIBILIDAD DE UNA DEMANDA ACERCA DE SU PROPIEDAD. SI i iSTRndesf.a ASISTENCIA PORUNA PERSONA QUE HABLA ESPANOL, LLAME USTED A (800)876-6144 Y UNA PERSONA LE AYUDARA TAX RECEIPT 01/05/2015 08:54AM ATASCOSA COUNTY TAX OFFICE 1001 OAK STREET JOURDANTON, TX 78026 IlSiillffiNuaSiliiil 1302446 w^mmsf- Ray|TientsTypej&a» o^/msP; RaymentjCode»i« Partial ***! Miiilitilfi Iiofliboj PAID BY: CASTRO MARY ANN PO BOX 495 PLEASANTON, TX 78064 [Property ID >' -V Geo Legal Acres 7" >~ ,*" 'Owner Name and Address \ • 17471"'•'""•""• ""j01?39-00-000-001104 9 4500 'CASTRO MANUEL &MARYANN PO BOX «195 j^; ./ . f"' : Legal Description PLEASANTON, TX 78064 JABSA0i23£I JPOITEVENT SV 1 9 45ACRES •A'Sifusf-'y'if. DBA Name : 'l501 OLIVE ST", ' ' Entity r Year Rate taxable Value/' Stmt #. Void _ Original Tax DiscjitJJg|g|^5SISl^Sll^S§M^ffl9lfflMi.' 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 0.07500 238,300 53838 12.50 0.00 3.00 2.33 0.00 17.83 ATASCOSA COUNTY 2013 0.34060 241,300 53838 56.72 0.00 13.62 10.55 0.00 80.89 100.00 Balance Due As Of 01/05/2015: 796.13 Ten'der;S5;!^*j|jii Details Description.^' * "l\ 7, ,rtS1'v Amount Money" Order '""""" 17-133811575 10000 100.00 ***Payment code of 'Partial' indicates this transaction is considered a partial payment. Please contact the Tax Office for balance due information. Operator•':TBatch " __ / *\ "r^ v '"__ •' Tota[Paid LH " 12840 (01/05/15LH) 10000 Special Condition Exists for this Property Page: 1 Receipt issued in Accordance with Section 31.075 of the Texas Property Tax Code True Automation, Inc. BSI Ftnjnctrtl Sen/ices, Inc. 10/09/2014 Sent Via Certified Mail 1307 HDD 1170 D77D 3513 bfl Mary Arm Castro PO Box 495 Pleasanton, TX 78064-0495 Loan Number: 44675 Property Address: 1501 OLIVE STREET JOURDANTON, TX 78026 NOTICE OF DEFAULT AND INTENT TO ACCELERATE Dear Mary Ann Castro: This letter is formal notice by BSI Financial Services, Inc. (herein as "BSI") the Servicer of the above-referenced loan, on behalf of MLB SUB I, LLC that you are in default under the terms of the documents creating and securing your Loan described above, including the Note and Deed of Trust/Mortgage/Security Deed ("Security Instrument"), for failure to pay the amounts due. The loan is due for 12/01/2011 and subsequent payments, plus late charges, fees and costs. As of today, the total delinquency and reinstatement amount is $73,967.02, which consists of the following: Next Payment Due Date 12/01/2011 Total Monthly Payments Due: $66,367.76 (35 @ $1,732.72) Late Charges $4,204.26 Other Fees: $3,395.00 Unapplied Balance: r$o.oo) TOTAL YOU MUST PAY TO CURE DEFAULT: $73,967.02 It is possible that after payment of the amounts detailed above there may be other fees still due and owing, including but not limited to other fees, escrow advances or corporate advances that BSI paid on your behalf or advanced to your account. This letter is a formal demand to pay $73,967.02. If the default, together with additional payments that subsequently become due, is not cured by 11/13/2014, BSI will accelerate the note so that the entire debt is immediately due and payable, and take steps to terminate your ownership in the property by a foreclosure proceeding or other action to seize the property. IF YOU ARE UNABLE TO BRING YOUR ACCOUNT CURRENT, BSI offers consumer assistance programs designed to help resolve delinquencies and avoid FORECLOSURE. These services are provided without cost to our customers. You may be eligible for a loan workout plan or other similar alternatives. If you would like to learn more about these programs, you may contact the Loss Mitigation Department at (800) 327-7861, Monday-Wednesday 8 am to 8 pm EST, Thursday 8 am to 6 pm EST, Friday 8 am to 5 pm EST, Saturday 8 am to 12 pm EST. WE ARE VERY INTERESTED IN ASSISTING YOU. The default above can be cured by payment of the total delinquency and reinstatement amount plus any W4 TX_NOI Page 1 of 3 1307 HDD 117D D77D 3S13 bfl additional payments and fees that become due by 11/13/2014. Note that in addition to the regular monthly payments, additional charges, costs and fees may become due during the period between today's date and the date the aforementioned payments are due. You may contact our Collection Department at (800) 327-7861 to obtain updated payment information. Please include your loan number and property address with your payment and send to: BSI FINANCIAL SERVICES PO BOX 517 TITUSVILLE, PA 16354 or Overnight BSI FINANCIAL SERVICES 314 S FRANKLIN ST TITUSVILLE, PA 16354 If you wish to dispute the delinquency, or if you dispute the calculation of amount of the delinquency and reinstatement amount, you may contact us by calling (800) 327-7861. You have the right to reinstate the loan after acceleration, and to bring a court action to assert the non-existence of a default or any other defense to acceleration or foreclosure sale. Failure to respond to this letter may result in the loss of your property. To the extent your obligation has been discharged or is subject to the automatic stay in a bankruptcy case, this notice is for informational purposes only and does not constitute a demand for payment or an attempt to collect a debt as your personal obligation. If you are represented by an attorney, please provide us with the attorney's name, address and telephone number. BSI is the mortgage servicer for the mortgagee of the Deed of Trust and the parties have entered into an agreement granting BSI authority to service the mortgage and represent the mortgagee (the "Servicing Agreement"). Pursuant to the Servicing Agreement, BSI is granted authority to collect and service debt associated with the Deed of Trust. Under §51.0025 of the Texas Property Code, BSI, as mortgage servicer, is authorized to administer any resulting foreclosure of the property covered by the Deed of Trust on behalf of the Mortgagee. All communication about your mortgage should be made through the Mortgage Servicing Department of BSI at 314 S Franklin Street, Titusville, PA 16354. Attention Servicemembers and Dependents: Assert and protect your rights as a member of the armed forces of the United States. If you are or your spouse is serving on active military duty, including active military duty as a member of the Texas National Guard or the National Guard of another state or as a member of a reserve component of the armed forces of the United States, please send written notice of the active duty military service to the sender of this notice immediately. Servicemembers on active duty, or a spouse or dependent of such a servicemember, may be entitled to certain protections under the Servicemembers Civil Relief Act ("SCRA") regarding the servicemember's interest rate and the risk of foreclosure. SCRA and certain state laws provide important protections for you, including prohibiting foreclosure under most circumstances. If you are currently in the military service, or have been within the last 12 months, AND joined after signing the Note and Security Instrument now in default, please notify BSI Financial Services, Inc. immediately. When contacting BSI Financial Services, Inc. as to your military service, you must provide positive proof as to your military status. Servicemembers and dependents with questions about the SCRA TX_NOI Page 2 of 3 130? HDD 1170 D770 3S13 bfl should contact their unit's Judge Advocate, or their installation's Legal Assistance Officer. Homeowner counseling is also available at agencies such as Military OneSource (www.militaryonesource.mil: 1-800-342-9647) and Armed Forces Legal Assistance (http://legalassistance.law.af.mil), and through HUD-certified housing counselors (http://www.hud.gov/offices/hsg/sfh/hcc/hcs.cfm). You can also contact us toll-free at (800) 327-7861 if you have questions about your rights under SCRA. If you are experiencing financial difficulty, you should know that there are several options available to you that may help you keep your home. You may contact a government approved housing counseling agency which provides free or low-cost housing counseling. You should consider contacting one of these agencies immediately. These agencies specialize in helping homeowners who are facing financial difficulty. Housing counselors can. help you assess your financial condition and work with us to explore the possibility of modifying your loan, establishing an easier payment plan for you, or even working out a period of loan forbearance. For your benefit and assistance, there are government approved homeownership counseling agencies designed to help homeowners avoid losing their homes. To obtain a list of approved counseling agencies, please call (800) 569-4287 or visit http://www.hud.gov/offices/hsg/sfli/hcc/hcs.cfm. You may be eligible for assistance from the Homeownership Preservation Foundation or other foreclosure counseling agency. You may call the following toll-free number to request assistance from the Homeownership Preservation Foundation: (888) 995-HOPE (4673). If you wish, you may also contact us directly at (800) 327-7861 and ask to discuss possible options. If your loan was originated as a Texas Home Equity Loan under the Texas Constitution, Article XVI, Section 50(a)(6), your property will be scheduled for foreclosure in accordance with Rules 735 and 736 of the Texas Rules of Civil Procedure and the Texas Constitution, by obtaining a court order for the foreclosure. This matter is very important. Please give it your immediate attention. Sincerely, BSI Financial Services, Inc. 314 S Franklin Street Titusville, PA 16354 (800)327-7861 FEDERAL LAW REQUIRES US TO ADVISE YOU THAT BSI FINANCIAL SERVICES, INC. IS A DEBT COLLECTOR AND THAT THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE. TO THE EXTENT YOUR OBLIGATION HAS BEEN DISCHARGED OR IS SUBJECT TO THE AUTOMATIC STAY IN A BANKRUPTCY PROCEEDING, THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND DOES NOT CONSTITUTE A DEMAND FOR PAYMENT OR AN ATTEMPT TO COLLECT AN INDEBTEDNESS AS YOUR PERSONAL OBLIGATION. IF YOU ARE REPRESENTED BY AN ATTORNEY, PLEASE PROVIDE US WITH THE ATTORNEY'S NAME, ADDRESS AND TELEPHONE NUMBER. TXNOl Page 3 of 3 13Q7 HDD 1170 D770 3S13 bfi