NO. 07FD2827

IN THE INTEREST OF §

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NUMBER TWO

IN THE COUNTY COURT AT LAW

KERISSA TOUCHSTONE AND

RICHARD DALE TOUCHSTONE

CHILDREN GALVESTON COUNTY, TEXAS

RESPONDENT'S AFFIDAVIT OF INABILITY TO PAY COSTS OF APPEAL

STATE OF TEXAS

GALVESTON COUNTY

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Before me, the undersigned notary, on this day personally appeared Elisa Marie Moreno, a person

whose identity is known to me.

1

After I administered an oath to her, upon her oath she said the following:

1. "My name is lisa Marie Moreno, and I am the Respondent in this case. I am of sound

mind and capable of making his affidavit. The facts stated within this affidavit are within my personal

knowledge and are true and c rrect.

2. "On March 10 2015, the trial court signed a final Order in favor of Petitioner and against

me in Cause Number 07FD28 7. After a timely Motion for New Trial was filed by the Attorney General's

Office, the Court signed an Or er Modifying the Judgment on May 15, 2015. I intend to appeal the court's

final judgment to the 1stor 14thCourt of Appeals in Houston.

3. "The estimate cost of the reporter's record is $522.50. I am unsure of the cost of the

clerk's record.

4. "I am unable t pay any of the court costs of the appeal.

5. "I have been nemployed since February 1, 2015. I collect unemployment income of $251

weekly. I have no other incom from any other source. See exhibit 1and incorporate by reference.

6 "I do not have a spouse.

7 "I have four (4 dependents, who are my children and who I am obligated to support. Two

of them live with me, Eleazar Pena who is 17 and Joshua Pena who is 15. Two of them, Kerissa and

Richard Touchstone, I am obi gated to support per this Court's order at $384 monthly plus an additional

$50 monthly in medical suppo

8. "I do not own ny real or personal property.

9. "I have no ca h and no money on deposit.

"I do own a vrhicle, a 1997 Chevy Lumina, which is worth about $500. I have no other

I

11. "My monthly expenses are: approximately $2000, and that includes $500 monthly rent,

$400 in food and supplies, $300 in utilities and telephone, $100 in clothing and laundry, $80 car insurance,

$150 in gas and repairs, plus the $384 and $50 ordered by this Court for Child support. My total monthly

income is only $1132, and that includes the food stamps.

10.

assets.

Filed: 6/8/2015 1:07:17 PM

JOHN D. KINARD - District Clerk

Galveston County, Texas

Envelope No. 5582618

By: Sara Redmond

6/8/2015 1:19:37 PM
12. "I am not able to obtain a loan to payfor the costs of the appeal as I have already reached

my maximum limit for borrowing from all known sources including friends and family.

13. "I am represented by legal counsel, who is providing services to me for free on this appeal,

but she cannot or will not pay the costs of the appeal.

14. "I am currently receiving public benefits, including Food Stamps and CHIP. I receive $45

monthly in food stamps. See exhibits 2 and 3, attached and incorporate by reference.

15. "I have neither the access to the equipment necessary nor the skill necessary to prepare

the appendix.

16. "Further affiant sayeth not."

~h1·bbwtr

ELISA MARIE MORENO

•• iw£Xi!,w,aAA,~Iib«R.q~ me by Elisa Mari~ roreno on June 8, 2015.

• m::;: E /JIJjl~ rJvJLiL t.(!nil

. STATE OF TEXASlftuE r:t&ary Public in and for ---->0<->..-_-

, - Comm. Exp. 02.20-~ The State of Texas

CERTIFICATE OF SERVICE

I certify that true a copy of the above was served on each attorney of record or party by a method

permitted by Rule 21a of the Texas Rules of Civil p~une~

, JULIA C. HATCHER

2
1887 1391-1 C18666

STATEMENT OF BENEFITS

TEXAS WORKFORCE COMMISSION

PO BOX 2211

MC ALLEN TX 78502-2211

Statement of Wages and Potential Benefit Amounts

Regular Unemployment Benefits:

Date Mailed: February 5, 2015

(All dates are in month/day/year order)

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ELISA M MORENO

14804 GAMBLE RD

SANTA FE TX 77517-3166

11'1111'111.1.1 •••• 11I••• 1•• 11'11.11.11 ••• 11•• 11,,"1 •• 1•• 11.1

Social Security Number: XXX-XX-7070

Dear ELISA M MORENO

Check your records! TWC has the wages below on file for you for the four quarters of your base

period. We use your base period wages to figure out whether you earned enough money to qualify for

unemployment insurance benefits and how much you could receive if you are eligible. After TWC looks

at whether you earned enough money to qualify, TWC looks at the reason you are no longer working to

decide whether you can receive bene·fits. Remember, even if you earned enough wages, TWC pays

benefits only if you meet the weekly requirements.

Please check the wage information carefully. If the employer name or the wage amount is incorrect, or

if an employer you worked for is missing, please contact a TWC Tele-Center immediately. More

information about correcting your wages is on the back of this form.

Based on the wages listed in the box below:

[Xl You earned enough in your base period to 0

receive unemployment benefits. if you are

otherwise E!ligible. i

i

You did not earn enough in your base

period to qualify for benefits.

0.00

0.00

0.00

0.00

2,933.44

0.00

0.00

1,361.44

4,914.00

5,803.13

0.00

0.00

5,803.13

4.294.88

4,914.00

Oct-Dee 2013 ~an-Mar 2014 Apr-Jun 2014 Jul-Sep 2014

FLUOR DANIEL SERVICES TX

FAMI LY DOLLAR STO~!ES OF TEXAS LLC I TX

SAFWAY SERVICES LLC . TX

'* You will receive a separate notice explaining why we did not use these wages.

The maximum weekly benefit amount in Texas this year is $ 465. Based on the wages above,

your weekly benefit amount is $ 251 .

The maximum amount you could receive during your benefit year is s ...,;4_;.;: _ 0.;.;:5...;.4

Your benefit year is the 52 weeks from 02-01-15 to 01-30-16

Keep in mind your benefits may run out before the benefit year ends.

See the back of this page for more information.

Claim 10.:

TWC Tale-phono No.:

02-{)l-15

(&00)939-6631

FOR HEARING IMPAIRED CLIENTS

Relay Texas TOO No.: 1-800-735-2989

Voice No.: 1-800-735-2988

BM100E 12/12/07
Form TF0001

August 2014

HHSC - MIDLAND

PO BOX 14900

MIDLAND TX 79711-4900

Date: 03/23/2015 Need help?

Call 2-1-1 or 1-877-541-7905

If you have a hearing or speech disability,

call 7-1-1 or any relay service.

All numbers are free to call.

~,TEXAS ~ ~_I. . Heattth and Human;

••• ( SewicesCommissron

Case Number: 1010526287

ELISA MARIE MORENO

14804 GAMBLE RD

SANTA FE TX 77517

Notice about your case:

SNAP Food Benefits

EDG number: 101496605

Who gets SNAP Food Benefits

Name Date Monthly Amount

Eleazar Pena Jr; Joshua Pena; Elisa Marie

03/01/2015 - 07/31/2015 $ 45.00 Moreno

Elisa Marie Moreno; Joshua Pena; Eleazar Pena 02/20/2015 - 02/28/2015 $ 93.00 Jr

Who can't get SNAP Food Benefits

Name Date

Richard Dale Touchstone III; Kerissa Renae Touchstone 02/20/2015

Notes:

Kerissa Renae Touchstone can't be part of this benefits case. - (TW A-231 , 1 TAC 372.151; 372.152;

372.153; 372.1508, 7 CFR 273.1 )

Richard Dale Touchstone III can't be part of this benefits case. - (TW A-231 , 1 TAC 372.151; 372.152;

372.153; 372.1508, 7 CFR 273.1 )

.

Health Care Benefits

Page 1 of 3

3769
Form TF0001

August 2014

W'ho gets health care benefits

Name EDG number Program Date

Children's Health 05/01/2015 -

Eleazar Pena Jr 631863789 Insurance Program 10/31/2015 (CHIP)

Children's Health 05/01/2015 -

Joshua Pena 631863790 Insurance Program 10/31/2015 (CHIP)

Who can't get health care benefits

Name EDG Number Program Date

Eleazar Pena Jr 637885791 Children's Medicaid 02/01/2015

Reason:

You are not eligible for benefits. -(TWA-2350, 1 TAC 366.215; 366.311; 366.409; 366.511; 366.615;

366.711; 366.811; 366.903, 42 CFR 435.919)

(Joshua Pena, Eleazar Pena Jr) isn't: (1) age 20 or younger, (2) age 65 or older, (3) pregnant, (4)

someone with a disability, (5) a dependent child on this case, OR (6) a child who didn't get SSI

(Supplemental Security Income) due to the August 1996 change in disability rules. - (TW A-825; A-221B

475.1.2, 1 TAC 366.307; 366.507; 366.611; 366.707; 366.807, 42 CFR 435.301)

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