ACCEPTED 13-14-00716-cv THIRTEENTH COURT OF APPEALS

CORPUS CHRISTI, TEXAS 6/17/2015 5:48:30 PM CECILE FOY GSANGER

CLERK

### CERTIFICATE OF COMPLIANCE Pursuant to TEX. R. APP. P. 9.4(i)(3), I certify thatthe foregoing document complies with the word count limitations set out in TEX. R. APP. P. 9.4(i). It contains 3,436 words, excluding any parts exempted byTEX. R. APP. P. 9.4(i)(1). In making this Certificate ofCompliance, I am relying on the word count provided by the software used to prepare the document. This is a computer-generated document created in Microsoft Word.



### CERTIFICATE OF SERVICE I hereby certifythat a true and correct copy ofthe foregoing Appellant's Opening Briefwas sent by Court's Efiling On this the 4th day ofJune, 2015 to: LINEBARGER GOGGAN BLAIR & SAMPSON, LLP Hon. Edward James Nicholas 4828 Loop Central Drive, Suite 600 Houston, Texas 77081

# APPENDIX 1

ORIGINAL PETITION FINAL SUMMARY JUDGEMENT CASE 2013-DCL-3455-D CAMERON COUNTY 103RD COURT HON.JANETH LEAL

### SUIT NO.

# 912-CrL,'?Jl_Jt:=j

# f1' 

# 0
CAMERON COUNTY, CITY OF BROWNSVILLE AND BROWNSVILLE INDEPENDENT SCHOOL DISTRICT 

# vs. VICTOR QUIJANO, DOING BUSINESS AS TARGET PEST CONTROL 

### § § § 

### § §
ORIGINAL PETITION TO THE

### HONORABLEJUDGE OF SAID COURT: I. 

### PLAINTIFF{S) INTHEDISTRICT COURT

JUDICIAL DISTRICT



### MAY 07 2013

This suit is brought for the recovery ofdelinquent ad valorem taxes under TEX. TAX CODE 

### § 33.41 by the following named Plaintiff(s), whether one or more, each ofwhich is a taxing unit and is legally constituted and authorizedto impose and collect taxes onproperty: 

### CAMERON COUNTY, CITY OF BROWNSVILLE AND BROWNSVILLE INDEPENDENT SCHOOLDISTRICT The Plaintiff(s) intends discovery to be conducted under Leve12 ofRule 190, Texas Rules of Civil Procedure. 

### DEFENDANT{S) The following are named as Defendant(s) in this suit, and they may be served with notice of these claims by service ofcitation atthe address and in the manner shown as follows: 

### Victor Quijano, Doing Business As, Target Pest Control, 35 Cuba St, Brownsville, TX 78526- 1832 ifliving, and ifany or all ofthe above named Defendant(s) be deceased, the unknown heirs ofeach or all ofthe said above named deceased persons; and the unknown owner or owners ofthe following described property; and the executors, administrators, guardians, legal representatives, devisees ofthe above named persons; and any and all other persons, including adverse claimants, owning or having any legal or equitable interest in or lien upon the below described property located in the county in whichthis suit is brought. The following taxing unit(s), whether one or more, is joined as a party herein as required by TEX. TAX CoDE§ 33.44(a) because it may have a claim and lien for delinquent taxes against all or part ofthe same property described below: 

### NONE. The foregoing named taxing unit(s), ifany, is invited to add its claim by intervening herein.

AV/Suit Key No. 2!851515

### II. Claims for all taxes becoming delinquent on said property at any time subsequent to the filing ofthis suit, up to the day ofjudgment, including all penalties, interest, attorney's fees, and costs on same, are incorporated in this suit, and Plaintiff(s) is entitled to recover the same, upon proper proof, without further citation ornotice. Plaintiff(s) is further entitled to recover each penalty that is incurred and all interest that accrues on all delinquent taxes imposed on the property from the date of judgment to the date ofsale. 

### III. As to each separately described property shown below, there are delinquent taxes, penalties, interest, and costsjustly due, owing and unpaid to Plaintiff(s) for the tax years and in the amounts as follows, ifpaid inMay 2013: PROPERTY AND AMOUNTS OWED ACCT.NO. 0001000211265002; INV,FURN,FIXT,VEHAT 35CUBA ST,BROWNSVILLE,TX CAMERON COUNTY TaxYear(s) Tax Amount Penalties and Interest TotalDue 2005 $43.33 $60.67 $104.00 2006 $34.62 $40.22 $74.84 2007 $48.12 $49.29 $97.41 2008 $34.97 $30.99 $65.96 2009 $53.83 $40.26 $94.09 2010 $53.95 $32.91 $86.86 2011 $55.64 $26.25 $81.89 TOTALS: $324.46 $280.59 $605.05 CITY OFBROWNSVILLE TaxYear(s) TaxAmount Penalties and Interest Total Due 2005 $38.86 $50.52 $89.38 2006 $37.16 $43.18 $80.34 2007 $37.18 $38.08 $75.26 2008 $37.18 $32.95 $70.13 2009 $40.98 $30.65 $71.63 2010 $41.20 $25.13 $66.33 2011 $43.89 $20.72 $64.61 TOTALS: $276.45 $241.23 $517.68 BROWNSVILLEINDEPENDENT SCHOOLDISTRICT Tax Year(s) 2005 2006 2007 TaxAmount $93.39 $80.32 $62.42 Penalties and Interest $121.41

$93.33 $61.17 TotalDue $214.80 $173.65 $123.59 AVISuitKeyNo. 218515162008 $62.42 $52.75 $115.17 2009 $68.43 $48.58 $117.01 2010 $68.43 $39.35 $107.78 2011 $68.43 $32.30 $100.73 

### TOTALS: $503.84 $448.89 $952.73 

### TOTALDUE $2,075.46 

### The total aggregate amount oftaxes, penalties, interest, and attorney's fees (ifany) for which Plaintiff(s) sues is $2,075.46, 

### subject to additional taxes, penalties, interest, and attorney's fees that accrue subsequent to the filing ofthis petition. IV. 

### All ofthe taxes were authorized by law and legally imposed in the county in which this suit is brought. The taxes were imposed in the amount(s) stated above on each separately described property for each year specified and on each person named, ifknown, who owned the property on January 1 of the year for which the tax was imposed. Plaintiff(s) now has and asserts a lien on each tract ofreal property and each item of personal property described herein to secure the payment of all taxes, penalties, interest and costs due. Pursuant to 

### Rule 54 

### of the Texas Rules of Civil Procedure, Plaintiff(s) affirmatively avers that all 

### things required by law to be 

### done have been done properly by the appropriate officials and all conditions precedenthave been met. 

# v. All ofthe property described above was, at the time the taxes were assessed, located within the territorial boundaries ofeachtaxing unit in whose behalfthis suit is brought. All Defendants named in this suit either owned the property thatis the subject ofthis suit on January 1ofthe year in which taxes were imposed on said property, or owned or claimed an interest in or lien upon said property at the time ofthe filing ofthis suit. The value ofany personal property that may be described above, and against which the tax lien is sought to be enforced, is in excess ofFIVE HUNDRED AND N0/100 DOLLARS ($500.00). VI. 

### The Law Firm represented by the attorney whose name is signed hereto is legally authorized and empowered to institute and prosecute this action on behalf of Plaintiff(s). Plaintiff(s) should recover attorney's fees as provided by law for the prosecution of this case, and such attorney's fees should be 

### taxed as costs. VII. 

### Plaintiff(s) may have incurred certain expenses in the form ofabstractor's costs in procuring data and information as to the name, identity and location of necessary parties, and in procuring necessary legal descriptions ofthe property that is the subject ofthis suit. Said expenses, ifincurred, are reasonable and are in the following amount: TO BE DETERMINED. The abstractor's costs, if any be shown, shouldbe taxed as costs herein.

AV/SuitKeyNo. 2185151 

# 7PRAYER WHEREFORE, PREMISES CONSIDERED, Plaintiff(s) requests that citation be issued and served upon each Defendant named herein, commanding them to appear and answer herein in the time and manner required by law. Plaintiff(s) further prays, upon final hearing in this cause, for foreclosure of its liens against the above-described property securing the total amount of all delinquent taxes, penalties and interest, including taxes, penalties and interest becoming delinquent during the pendency ofthis suit, costs ofcourt, attorney's fees, abstract fees, and expenses offoreclosure sale. Plaintiff(s) further prays for personaljudgment against Defendant(s) who owned the property on January 1 ofthe year for which the taxes were imposed for all taxes, penalties, interest, and costs that are due or will become due on the property, together with attorney's fees and abstractor's fees. Plaintiff(s) further prays for: (1) the appropriate order ofsale requiring the foreclosed property to be sold, free and clear of any right, title or interest owned or held by any ofthe named
. Defendants, at public auction in the mannerprescribed by law, and (2) writs ofexecution, directing the sheriffs and constables for the State ofTexas, to search out, seize, and sell sufficient property ofthe Defendant(s) against whom personal judgment may be awarded to satisfy the lawfuljudgment sought herein. Finally, Plaintiff(s) prays for such other and further relief, at laworin equity, to which itmay show itself justlyentitled. Respectfully submitted, LINEBARGER GOGGAN BLAIR & SAMPSON, LLP 1805 RUBEN TORRES BLVD. SUITEB-28 BROWNSVILLE, TX 78521 (956) 546-1216 (956) 546-1624

- FAX

John D. Guevara State BarNo. 24031408 Rogelio Ortiz, Jr State BarNo. 24053405 Monica Solis State BarNo. 24058260 Attorney for Plaintiffs

AV/SuitKeyNo. 21851518CIVILCASEINFORMATION SHEET CAUSE NUMBER (FOR CLERKUSE ONLY):**------~-----COURT** (FOR CLERK USE ONLY):
___JUDICIAL DISTRICT STYLEDCAMERONCOUNTY.CITY OFBROWNSVILLEAND BROWNSVILLEINDEPENDENT SCHOOLDISTRICT VS.VIC[ORQUIJANO.DOINGBUSINESSASTARGETPESTCONTROL (e.g., John Smith v. All American 11lSUl1111Ce Co; In re MaryAnn Jones; IntheMatter oftheEstate ofGeorge Jackson) Acivil case information sheet must be completed and submitted when an original petition or application is filed to initiate anew civil, family law, probate, or mental health case or when a post-judgment motion for modification or enforcement is filed in a fumily law case. The information should be the best available at the time of filing. This sheet, approved by the Texas Judicial Council, is intended to collect information that will be used for statistical purposes only. lt neither replaces nor supplements the filings or service ofpleading or other documents as required by law or rule. The sheet does not constitute a discovery l'(l(luest, resPOnse, or SUI>lllementation, and it isnot admissible at trial. 

### 1;.Contactiki!omu!tioitior**pe~it**

### c.0m1Jletrua•·casitl)fori'ilatiou shett:• 

### Names of'llarilesIn

### ease:.· J:'enoo OtentitytompletiD2 stu:etis: Name: Email: Plaintift{s)/Petitioner{s): Attorney for Plaintift7Petitioner John D. Guevara jobn.guevara@lgbs.com Pro Se Plaintift7Petitioner Cameron Coonty Title IV-D Agency Address: 1805 Ruben Torres Blvd Telephone: (956) 546-1216 Defendant(s)/Respondent(s): Other: Ste B-28 (956) 546-1624- Fax City/State/Zip: Brownsville, TX Victor Quijano Doing Business As, Additional Parties in Child SupportCase: 78521 StateBarNo. 24031408 TargetPest Control Custodial Parent

# ~J~ Additio111l Plaintiff(s)/l'etilioner(s)and Non-Custodial Parent: Defendalll(s)!Respondent(s) on page 2 Presumed Father:

2, Indicate ease type.orldentilythe m()Bt imll0rta.nti$$Ue In the ease (ulectonlY 1): Civil Family Law

: ... :···· Poat•judgnteatAetlons ContraCt ... ' •' IJ1Jurr**or-Daliiji~e** . 

### .. Reail'roptJ'tY · Mama2eRdatiooshlp · (Jiini•Title**IV~D)** · Debt/Contract 

# l"""'lt/8"""**~inent** Domain/ nulment [Enforcement

### ~~~TPA Construction Condemnation Declare Marriage Void !Modification-Custody '·' bt/Contract Defamation

## ~riloo Divorce


## - !Modification-Other
• l·

. raud/Misrepresentation

# M~~ QuietTitle EithChildren**TltlelV~D**

:· her Debt/Contract: · Accounting espass to Try Title oChildren Enforcement/Modification Legal her Property: Paternity Foreclosure Medical !Reciprocals (UIFSA)**~me** Equity-Expedited cr Professional !supportOrder herForeclosure Liability: · Relatedto Crinilnat**~Franchise ~Motor** Vehicle Accident Matters OtherFamUy .Law
.:Piireitt;.{:blldRelationship l'illnsurance Premises Expunction III!Enforce Foreign**~~~~doption/Adoption** With '· Landlordffenant ProductLiability udgmentNisi Judgment Termination

Non-Competition**~bestos/Silica** Non-Disclosure 

# r-- •!Child Protection •; Partnership · Other Product Liability Seizure!Forfeiture ameChange iehild Support Jijj Other Contract: List Product: Writ ofHabeas Corpus- rotective Order [custody orVisitation i!OtherInjury or Damage: Pre-indictment Removal ofDisabilities Gestational Parenting 1l0ther: ofMinority Crandparent Access I)

Other: Paternity/Parentage Employment 

### ·· :OtiterCivil !TerminationofParental !i';Piscrimination**~inistrative** Appeal 

# 1 _ rn... ,"" Rights !" Retaliation titrust/Unfair erpetuate Testimony**~~other**Parent-Child: ';·Termination Competition curities!Stock ' !Workers' Compensation Code Violations ortious Interference Iii!:**~her** Employment: 'Foreign Judgment Other: ntellectual Property Tu Probate &Mental Health

# ~u-• Probate/WI/IsllnJestateAdministration puardianship-Adult ax Delinquency**~ependent** Administration Guardianship-Minor therTax ndependent Administration ;Mental Health ther Estate Proceedings Other: 3. Indicate procedure orremedy, ifapplicable_(ma.v.selectnwrethtm.tl:

' Appeal from Municipal orJustice Court !DeclaratoryJudgment 'PrejudgmentRemedy •! Arbitration-related !Garnishment Protective Order

Attachment**~nterpleader** !Receiver 

### fBill ?fR:view ll"icense Sequestration**~an**damus [remporary Restraining Order/Injunction Action tl'ost-judgment trumover AV/SuitKeyNo. 2185159

### Additional Plaintiffs: City OfBrownsville Brownsville Independent School District 

### AdditionalDefendants:
Rendition Penalty

AV/SuitKeyNo.

# 2185110SUIT NO. 2013-DCL-3455-D CAMERON COUNTY, CITYOF BROWNSVILLEAND BROWNSVILLE INDEPENDENT SCHOOL DISTRICT 

### § 

### § 

# vs. § § VICTOR QUIJANO , DOING BUSINESS AS 

### § TARGETPEST CONTROL JUDGMENT IN THE DISTRICT COURT

103RD JUDICIAL DISTRICT
CAMERON COUNTY, TEXAS

BE IT REMEMBERED that on the 18th day of November, 2014, came on to be heard in regular order the above numbered and entitled cause wherein CAMERON COUNTY, CITY OF BROWNSVILLE AND BROWNSVILLE INDEPENDENT SCHOOL DISTRICT are the Plaintiffs; and wherein the Defendant is Victor Quijano Doing Business As, Target Pest Control who was duly served with process as required by law, appeared and was duly notified ofthis setting; This cause came on for trial and Plaintiffs having moved the Courtto dismiss from this suit any parties not named above, it was so ordered; and ajury being waived, the parties submitted all matters ofcontroversy, both offact and oflaw, to the Court without the intervention ofajury, and the Court, having heard the pleadings, the evidence, and the argument ofcounsel, is ofthe opinion and finds as follows: The above named Defendant(s) was the owner(s) on January 1 ofeach ofthe tax years shown to be delinquent on the property described below. There are taxes, penalties, interest, and costs due, owing, and unpaid to Plaintiffs upon the property inthe amount set out below. IT IS THEREFORE ORDERED, ADJUDGED, and DECREED that there is due, owing, and unpaid to Plaintiffs the following amounts ofdelinquent taxes, accrued penalties, interest, attorney fees and costs for all delinquent years upon the following described property as set out below, together with additional penalties and interest attherates prescribed by Subchapters A and C ofChapter 33, Property Tax Code, which accrue hereafter on all ofsaid taxes from date of judgment until paid. PROPERTYAND AMOUNTS OWED ACCT. NO. 0001000211265002; INV,FURN,FIXT,VEH AT 35 CUBA ST,BROWNSVILLE,TX CAMERON COUNTY Year(s) Due: 2005-2009 CITY OFBROWNSVILLE Year(s) Due: 2005-2009

SuitNo. 2013-DCL-3455-D Page 1 $481.14 $426.34

SuitKey Noi

# 'g 151,/.'



### BROWNSVILLE INDEPENDENT SCHOOLDISTRICT Year(s) Due: 2005-2009 $819.31 TOTAL DUE: $1,726.79 All ofthe property described above was, at the time that taxes were assessed, located within the territorial boundaries ofthe Plaintiffs, and the taxes were imposed in Cameron County, Texas. IT IS FURTHER ORDERED, ADruDGED AND DECREED that Plaintiffs recover(s) ofand from Defendant(s) personal judgment for the heretofore set out taxes, accrued penalties, interest, attorney fees, costs, and all costs of suit, together with additional penalties and interest at the rates prescribed by Subchapters A and C ofChapter 33, Property Tax Code, which accrue hereafter on all of said taxes from date of judgment until paid, for which let execution issue. All reliefprayed for in any ofthe pleadings in this cause which is not specifically granted by this judgment is hereby denied. This judgment finally disposes of all parties and all claims and is appealable. SIGNED 

### on

# the~ day 

### of

# j1}Q~J ,

# 20d.

Approved:

John D. Guevara State BarNo. 24031408 john.guevara@lgbs.com Rogelio Ortiz, Jr State Bar No. 24053405 rogelio.ortiz@lgbs.com Monica Solis State BarNo. 24058260 monica.solis@lgbs.com Attorney for: Plaintiffs

SuitNo. 2013-DCL-3455-D FIL[J

# ~'CLOCKill AURORA DE LA GARZA, CLERK 

### DEC 0I 2014

Page2**SuitKeyN~CJSJ**

# APPENDIX 

# 2

TEXAS TAX CODE CHAPTER § 11.145, § 11.254, § 23.121, 23.1241, 23.124, 23.127, § 23.24, § 22.01

### Sec. 11.145. INCOME-PRODUCING TANGIBLE PERSONAL PROPERTY HAVING VALUE OF LESS THAN $500. (a) A person is entitled to an exemption from taxation ofthe tangible personal propertythe person owns that is held or used forthe production of income ifthat property has a taxable value of less than $500. (b) The exemption provided by Subsection (a) applies to each separate taxing unit in which a person holds or uses tangible personal propertyfor the production of income, and, forthe purposes ofSubsection (a), all property in each taxing unit is aggregated to determine taxable value. Sec. 11.254. MOTOR VEHICLE USED FOR PRODUCTION OF INCOME AND FOR PERSONAL ACTIVITIES. (a) Except as provided by Subsection (c), an individual is entitled to an exemption from taxation of one motorvehicle owned by the individual that is used in the course ofthe individual's occupation or profession and is also used for personal activities ofthe ownerthat do not involve the production of income. (b) In this section, "motorvehicle" means a passenger car or lighttruck as those terms are defined by Section 502.001, Transportation Code. INVENTORY. (a) Except as provided by Sections 23.121, 23.1241, 23.124, and 23.127, the market value of an inventory is the price for which it would sell as a unitto a purchaser who would continue the business. An inventory shall include residential real property which has never been occupied as a residence and is held for sale in the ordinary course of a trade or business, provided that the residential real property remains unoccupied, is not leased or rented, and produces no income. (b) The chief appraiser shall establish procedures for the equitable and uniform appraisal of inventoryfortaxation. In conjunction with the establishment ofthe procedures, the chief appraiser shall: (1) establish, publish, and adhere to one procedure for the determination ofthe quantity of property held in inventorywithout regard to the kind, nature, or character ofthe property comprising the inventory; and (2) applythe same enforcement, verification, and audit procedures, techniques, and criteria tothe discovery, physical examination, or

### quantification ofall inventories without regard tothe kind, nature, or character ofthe property comprising the inventory. (c) In appraising an inventory,the chiefappraiser shall use the information obtained pursuantto Subsection (b) ofthis section and shall apply generally accepted appraisal techniques in computingthe market value as defined in Subsection (a) ofthis section. Acts 1979, 66th Leg., p. 2253, ch. 841, Sec. 1, eff. Jan. 1, 1982. Amended by Acts 1981, 67th Leg., 1st C.S., p. 137, ch. 13, Sec. 58, eff. Jan. 1, 1982; Acts 1987, 70th Leg., ch. 590, Sec. 1, eff. Aug. 31, 1987; Acts 1989, 71st Leg., ch. 796, Sec. 16, eff. Sept. 1, 1989; Acts 1993, 73rd Leg., ch. 672, Sec. 1, 2, eff. Jan. 1, 1994; Acts 1995, 74th Leg., ch. 836, Sec. 1, 2, eff. Jan. 1, 1996; Acts 1995, 74th Leg., ch. 945, Sec. 1, eff. Jan. 1, 1996; Acts 1997, 75th Leg., ch. 165, Sec. 31.01{73), eff. Sept. 1, 1997; Acts 1997, 75th Leg., ch. 1112, Sec. 1, eff. Jan. 1, 1998; Acts 1997, 75th Leg., ch. 1184, Sec. 1, eff. Jan. 1, 1998. Sec. 23.24. FURNITURE, FIXTURES, AND EQUIPMENT. (a) Ifreal propertyis appraised by a method thattakes into account the value of furniture, fixtures, and equipment in oron the real property,the furniture, fixtures, and equipment shall not be subjectto additional appraisal ortaxation as personal property. (b) In determiningthe market value ofthe real property appraised on the basis ofrental income, the chiefappraiser may not separatelyappraise or take into account any personal propertyvalued as a portion ofthe income of the real property, and the market value ofthe real property must include the combined value ofthe real property and the personal property. Added by Acts 1999, 76th Leg., ch. 479, Sec. 1, eff. Sept. 1, 1999. Amended by: Acts 2009, 81st Leg., R.S., Ch. 1211 (S.B. 771), Sec. 2, eff. January 1, 2010.
§ 

### 22.01. Rendition Generally (a) Except as provided by Chapter 24, a person shall renderfor taxation all tangible personal property used for the production of income thatthe person owns orthatthe person manages and controls as a fiduciary on January 1. Arendition statement shall contain: (1) the name and address ofthe propertyowner; (2) a description ofthe propertyby type or

### category; (3) ifthe property is inventory, a description of each type of inventory and a general estimate ofthe quantity ofeach type of inventory; (4) the physical location ortaxable situs ofthe property; and (5) the propertyowner's good faith estimate ofthe market value ofthe property or, at the option ofthe property owner, the historical cost when new and the year of acquisition ofthe property.

# APPENDIX 3
LETTER FROM APPELLANT TO COURTAURORA DE LA GARZA CLERK OF THE DISTICT COURTS OF CAMERON COUNTY,TEXAS 974 EHARRISON ST BROWNSVILLE,TX 78520 SUIT #2013-DCL-3455-D JUNE 11,2013 

## ··S.\ 

# {:J**FILED~O'CLOCK_M** AURORA DE LA GARZA. CLERK 

### JUN 1 3 

### 2013

I have being out of business since 2008(copy ofthe state comptroller says 2009), but I have call before to explain we were broke and going out of business, since 2008 we no longer rented on Boca Chica Towers ,this the only address for business(2100 Boca Chica blvd suite 308),not 35 Cuba st which is my residence and before I did not own anything I subcontracted services, so I didn't have equipment, vehicles, etc .(Can check in the motorvehicle department),The office that we rented came with a desk and the phone. A business was in 2100 Boca chica blvd suite 308 very ,very small lOft by 5ft, so just a desk a chair and phone no computer. Nothing ofvalue that can be appraised. I went to the Appraisal district several times and made clear that I was subcontracting services, that I didn't own anything and invited them to check nobody came, theyjust keep sending the appraisal value which whatever numbers they figure out, but nobody listen I send the appraisal forms back but they came back next year, so I didn't waste my time anymore on going to San Benito to the Appraisal district. So to make things clear I went out of business, I don't have anything ofthat business no vehicles or equipment, I don't have anything ofvalue, the only thing I have is my home which I am paying mytaxes every year and I am current in 35 Cuba st, there is no business is just my residence where I live with my family. And I can't figure it out ifbeing out of business since 2008, this people continue taxing you, it is sad and waste of moneyfrom us tax payers that they don't even check with the State Comptroller if businesses

e end ofthis harassment and notify the district to clear my case



# 14

# APPENDIX 4

LETTER FROM COMPTROLLERS OFFICE STATING WHERE BUSINESS WAS LOCATED AND DATE WAS CLOSED.

# COMPTROLLER OF PUBLIC ACCOUNTS STATE OFTEXAS

AUSTIN, 78774

BROWNSVILLE ENFORCEMENT OFFICE 1900 N EXPRESSWAY, STE C-1 BROWNSVILLE, TEXAS 78521-1563 June 

### 12, 2013

TO WHOM IT MAY CONCERN: This is to confirm that Victor M. Quijano, with taxpayer number 32000548068, closed the business known as 

### Target Pest Control, located at 2100 Boca Chica Ste. 308, Brownsville, 

### TX, .78521, as 

### ofDecember 25, 2009. Ifyou should have any questions, please do not hesitate to call ouroffice at (956)542-8426.

# oUAlonzo Vidal Enforcement Officer Brownsville Enforcement Office

- 2H25

an equal opportunity employer 

# 15

# APPENDIX 

# 5

CERTIFY LETTER OF SUBCONTRACTORJuly 15,2009

WHOM IT MAY CONCERN;

I LEONARDO SCHWEBEL WORK FOR Mr.QUIJANO FROM 2005 TO 2008 WHEN IT WAS CLOSED, IN BUSINESS NAME TARGET PEST CONTROL AS A SUBCONTRACTOR USING MY TRUCK AND EQUIPMENT TO PERFORM WORK IN PEST CONTROL ,AND WAS THE ONLY WORKER THIS COMPANY HAD. I AM EXEMPT OF TAX PROPERTY BECAUSE I USED MY VEHICLE A 96 MAZDA PICKUP FOR WORK AND PERSONAL USED THAT WAS NOT INVOLVE IN THE PRODUCTION OF INCOME.(SEC.11.254 TEX TX CODE ANN) THE ADRESS WHERE BUSINESS WAS 2100 BOCA CHICA STE 308,BROWNSVILLE,TX, WHICH I ATIEND PERSONALLY ANSWERING CALLS AND DOING SERVICES. THE ONLY PROPERTY FROM MR

. QUIJANO WAS A DESK AND A CHAIR, ALL THE OTHER IMPLEMENTS FOR WORK WERE OF MY PROPERTY.(PLASTIC SPRAYER WORTH $15.00) AND INSECTICIDE AS NEEDED.

LEO SCHWEBEL

.. '\t-"v ,,,,',,, JAQ**>~ ···** **·· ::-** **~** UHINE INFANTE**~**...:. ( @ Notary Public

. State ot Texa

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