HARRIS COUNTY'S ORIGINAL INTERVENTION July 24, 2023 (2024)

On May 10, 2023 aHARRIS COUNTY'S ORIGINAL INTERVENTIONwas filedinvolving a dispute betweenCity Of Baytown,Goose Creek Consolidated Independent School District,Harris County,Harris County Department Of Education,Harris County Hospital District,Lee College District,Port Of Houston Authority Of Harris County Tx,andMarie, Alvin Jean,for TAX SUITin the District Court of Harris County.

 
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 CAUSE NOCITY OF BAYTOWN IN THE DISTRICT COURT OF HARRIS COUNTY, TEXASALVIN JEAN MARIE JUDICIAL DISTRICT HARRIS COUNTY’S ORIGINAL INTERVENTIONTO THE HONORABLE JUDGE OF SAID COURT:Pursuant to Rule 60 of the Texas Rules of Civil Procedure and Section .44 of the Texas PropertyTax Code this claim for the recovery of delinquent ad valorem taxes, penalties, interest, andattorney’s fees is filed by the following named Intervenor(s), by and through the undersignedAssistant County Attorney of the Office of the Harris County Attorney, and would show the Courtas follows: Intervenor(s): HARRIS COUNTY for itself and for the following countywide taxing entities: HARRIS COUNTY FLOOD CONTROL DISTRICT PORT OF HOUSTON AUTHORITY OF HARRIS COUNTY HARRIS COUNTY HOSPITAL DISTRICT and HARRIS COUNTY DEPARTMENT OF EDUCATION Intervenor adopts and incorporates hereinafter Plaintiff’s Original Petition as may be amended. Defendant(s) are those individuals and/or entities named in the Plaintiff’s Original Petition and Amended Petitions filed herein, and all persons owing, having, or claiming any interest or lien in the property( described in this Petition. Defendant shall be served with notice of these claims in accordance Rules and 21a of the Texas Rules of Civil Procedure. As to each separately described property, there are delinquent taxes, penalties, interest, and cost associated with the lawsuit, justly due, owing, and unpaid against the property( described as follows:HCAD NO 0730680100006PROPERTY DESCRIPTION:HARRIS COUNTY Delinquent Penalties Attorney’s Fees Tax Year Total Due Base Levy & Interest (§ 33.48) 2022 $373.83 $67.29 $0 $441.12 TOTAL DUE: $441.12 6. That all parties to this suit, including Plaintiff, Defendant(s) and Intervenor(s), shall take notice that claims for any and all taxes becoming delinquent on the property(ies) at any time subsequent to the filing of this action up to the day of Judgment, are incorporated in this suit; and upon request therefore, shall be recovered without further Citation or notice, and that these claims for delinquent taxes shall include all penalties, interest and costs allowed by law. 7. All of these taxes were legally imposed in the county in which this suit is filed, in the stated amount of each separately described properties for each year specified, and on each person named, if known, who owned the properties on January 1 of the year for which the tax was imposed. 8. Intervenor(s) now has and asserts a lien on each of the properties described above to secure the payment of all taxes, penalties, interest, and costs due. All things required by law to be done have been done properly by the appropriate officials. 9. All of the properties described above were, at the time the taxes were assessed, located within the boundaries of the Intervenor(s) on whose behalf this suit is brought. The person(s) sued owned the properties at the time of the filing of this suit. 10. Reasonable attorney's fees should be awarded in favor of the Intervenor(s) for the prosecution of this case, where applicable under Section 33.48 of the Texas Property Tax Code, and these attorney's fees should be taxed as costs. In addition, Intervenor(s) may have incurred certain expenses in procuring data and information as to the name, identity, and location of necessary parties and in procuring necessary legal descriptions of the properties.11. WHEREFORE, PREMISES CONSIDERED, Intervenor(s) prays that the Defendant(s) be cited to appear and answer in the time and manner required by law, and that on final trial, judgment be entered against the Defendant(s) for the total amount of taxes, penalties and interest due, to include all additional taxes, penalties and interest which may come due during the pendency of this action. Intervenor(s) further prays for foreclosure of the tax lien on the specific properties of the Defendant(s) and that this Court enter and order in a manner required by law, and for the issuance of the appropriate writs of execution, directing the Sheriff or Constable to search out, seize and sell sufficient properties of the Defendant(s) to satisfy the judgment. Intervenor(s) further prays for costs of court, reasonable attorney's fees, and for all other relief, at law or in equity, as justly entitled. Respectfully submitted, Office of Harris County Attorney Christian D. Menefee 1019 Congress, 15th Floor Houston, Texas 77002-1700 Email: TaxEservice.cao@harriscountytx.gov Phone: 346-286-8787 /s/ Steven N. Dieu STEVEN N. DIEU, Assistant County Attorney State Bar #: 00787366 HARRISON LONG, Assistant County Attorney State Bar #: 24132355 CLYDE LEUCHTAG, Assistant County Attorney State Bar #: 12243250 JAMES HARRIS, Assistant County Attorney State Bar #: 24049808 Attorney for Intervenor(s) CERTIFICATE OF SERVICEI certify that a true and correct copy of the foregoing has been sent by electronic mail, facsimile orcertified mail, return receipt requested, to the following parties:Alvin Jean Marie1900 E. Fayle St.Baytown, Texas 77520Randall B. StrongAttorney for City of Baytown407 W. Baker Rd., Suite ZBaytown, Texas 77521Email: randy.strong@randallbstrong.comLinebarger, Goggan Blair & SampsonPO Box 3064Houston, Texas 77253Cinthya ReadeAttorney for Lone Star College DistrictHarris County Emergency Services District # 01Harris County Emergency Services District # 24Email: cinthya.reade@lgbs.comReid, Strickland & Gillette, L.L.PPO Box 809Baytown, TX 77522Brandon BenoitAttorney for Goose Creek CISD &Lee College DistrictEmail: tax@rsg-llp.comin accordance with the Texas Rules of Civil Procedure on July 24, 2023. /s/ Steven N. Dieu Steven N. Dieu, Assistant County Attorney Attorney Certifying 

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