ACCEPTED

13-14-00716-cv

THIRTEENTH COURT OF APPEALS

CORPUS CHRISTI, TEXAS

6/17/2015 5:48:30 PM

CECILE FOY GSANGER

CLERK

 FILED IN 13th COURT OF APPEALS CORPUS CHRISTI/EDINBURG, 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 that the 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 by TEX. R. APP. P. 9.4(i)(1). In making this Certificate of Compliance, 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 certify that a true and correct copy of the foregoing Appellant's Opening Brief was 

sent by 

Court's Efiling 

On this the 4th day of June, 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 HONORABLE JUDGE OF SAID COURT: 

I. 

PLAINTIFF{S) 

IN THE DISTRICT COURT 

JUDICIAL DISTRICT 

MAY 0 7 2013 

This suit is brought for the recovery of delinquent ad valorem taxes under TEX. TAX CODE § 

33.41 by the following named Plaintiff(s), whether one or more, each of which is a taxing unit and is 

legally constituted and authorized to impose and collect taxes on property: 

CAMERON COUNTY, CITY OF BROWNSVILLE AND BROWNSVILLE INDEPENDENT 

SCHOOL DISTRICT 

The Plaintiff(s) intends discovery to be conducted under Leve12 of Rule 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 of citation at the address and in the manner shown as follows: 

Victor Quijano, Doing Business As, Target Pest Control, 35 Cuba St, Brownsville, TX 78526-

1832 

if living, and if any or all of the above named Defendant( s) be deceased, the unknown heirs of each or 

all of the said above named deceased persons; and the unknown owner or owners of the following 

described property; and the executors, administrators, guardians, legal representatives, devisees of the 

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 

which this 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 

of the same property described below: NONE. The foregoing named taxing unit(s), if any, 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 

of this suit, up to the day of judgment, 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 or notice. 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 of sale. 

III. 

As to each separately described property shown below, there are delinquent taxes, penalties, 

interest, and costs justly due, owing and unpaid to Plaintiff(s) for the tax years and in the amounts as 

follows, if paid in May 2013: 

PROPERTY AND AMOUNTS OWED 

ACCT. NO. 0001000211265002; INV ,FURN,FIXT,VEH AT 35 CUBA ST,BROWNSVILLE,TX 

CAMERON COUNTY 

Tax Year(s) Tax Amount Penalties and Interest Total Due 

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 OF BROWNSVILLE 

Tax Year(s) Tax Amount 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 

BROWNSVILLE INDEPENDENT SCHOOL DISTRICT 

Tax Year(s) 

2005 

2006 

2007 

Tax Amount 

$93.39 

$80.32 

$62.42 

Penalties and Interest 

$121.41 

$93.33 

$61.17 

Total Due 

$214.80 

$173.65 

$123.59 

AVISuitKeyNo. 21851516 
2008 $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 

TOTAL DUE $2,075.46 

The total aggregate amount of taxes, penalties, interest, and attorney's fees (if any) 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 of this petition. 

IV. 

All of the 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, if known, 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 of real 

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 precedent have been met. 

v. 

All of the property described above was, at the time the taxes were assessed, located within the 

territorial boundaries of each taxing unit in whose behalf this suit is brought. All Defendants named in 

this suit either owned the property that is the subject of this suit on January 1 of the year in which taxes 

were imposed on said property, or owned or claimed an interest in or lien upon said property at the 

time of the filing of this suit. The value of any personal property that may be described above, and 

against which the tax lien is sought to be enforced, is in excess of FIVE HUNDRED AND N0/1 00 

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 of abstractor's costs in procuring 

data and information as to the name, identity and location of necessary parties, and in procuring 

necessary legal descriptions of the property that is the subject of this suit. Said expenses, if incurred, 

are reasonable and are in the following amount: TO BE DETERMINED. The abstractor's costs, if 

any be shown, should be taxed as costs herein. 

AV/SuitKeyNo. 2185151 7 
PRAYER 

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 

of this suit, costs of court, attorney's fees, abstract fees, and expenses of foreclosure sale. Plaintiff(s) 

further prays for personal judgment against Defendant(s) who owned the property on January 1 of the 

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 of sale requiring the foreclosed property to be sold, free and clear of 

any right, title or interest owned or held by any of the named . Defendants, at public auction in the 

manner prescribed by law, and (2) writs of execution, directing the sheriffs and constables for the State 

of Texas, to search out, seize, and sell sufficient property of the Defendant(s) against whom personal 

judgment may be awarded to satisfy the lawful judgment sought herein. Finally, Plaintiff(s) prays for 

such other and further relief, at law or in equity, to which it may show itself justly entitled. 

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 Bar No. 24031408 

Rogelio Ortiz, Jr 

State Bar No. 24053405 

Monica Solis 

State Bar No. 24058260 

Attorney for Plaintiffs 

AV/SuitKeyNo. 21851518 
CIVIL CASE INFORMATION SHEET 

CAUSE NUMBER (FOR CLERK USE ONLY): ------~-----COURT (FOR CLERK USE ONLY): ___ JUDICIAL 

DISTRICT 

STYLED CAMERON COUNTY. CITY OF BROWNSVILLE AND BROWNSVILLE INDEPENDENT SCHOOL DISTRICT 

VS. VIC[OR QUIJANO. DOING BUSINESS AS TARGET PEST CONTROL 

(e.g., John Smith v. All American 11lSUl1111Ce Co; In re Mary Ann Jones; In the Matter ofthe Estate of George Jackson) 

A civil case information sheet must be completed and submitted when an original petition or application is filed to initiate a new 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 of pleading 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 is not admissible at trial. 

1; .Contact iki!omu!tioitior pe~it c.0m1Jletrua•·casitl)fori'ilatiou shett:• Names of'llariles In ease:.· J:'enoo Ot entity tompletiD2 stu:et is: 

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 Support Case: 

78521 State Bar No. 24031408 Target Pest Control Custodial Parent 

~J~ 

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

Presumed Father: 

2, Indicate ease type. or ldentilythe m()Bt imll0rta.nti$$Ue In the ease (ulect onlY 1): 

Civil Family Law : ... :···· Poat•judgnteatAetlons 

ContraCt ... ' •' IJ1Jurr or-Daliiji~e . .. Reail'roptJ'tY · Mama2e Rdatiooshlp · (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~~ Quiet Title Eith Children 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 !support Order 

her Foreclosure Liability: · Related to Crinilnat ~Franchise ~Motor Vehicle Accident Matters Other FamUy .Law . :Piireitt;.{:blld Relationship 

l'illnsurance Premises Expunction III!Enforce Foreign ~~~~doption/Adoption With 

'· Landlordffenant Product Liability udgment Nisi Judgment Termination 

Non-Competition ~bestos/Silica Non-Disclosure r-- • !Child Protection 

•; Partnership · Other Product Liability Seizure!F orfeiture ameChange iehild Support 

Jijj Other Contract: List Product: Writ of Habeas Corpus- rotective Order [custody or Visitation 

i!Other Injury or Damage: Pre-indictment Removal of Disabilities Gestational Parenting 

1l0ther: of Minority Crandparent Access 

I) Other: Paternity/Parentage Employment · · :Otiter Civil !Termination of Parental 

!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/IsllnJestate Administration puardianship-Adult 

ax Delinquency ~ependent Administration Guardianship-Minor 

therTax ndependent Administration ;Mental Health 

ther Estate Proceedings Other: 

3. Indicate procedure or remedy, ifapplicable_(ma.v.selectnwrethtm.tl: 

' Appeal from Municipal or Justice Court !Declaratory Judgment 'Prejudgment Remedy 

•! Arbitration-related !Garnishment Protective Order 

Attachment ~nterpleader !Receiver 

fBill ?fR:view ll"icense Sequestration 

~an dam us [remporary Restraining Order/Injunction 

Action tl'ost-judgment trumover 

AV/SuitKeyNo. 2185159 
Additional Plaintiffs: 

City Of Brownsville 

Brownsville Independent School District 

Additional Defendants: 

Rendition Penalty 

AV/SuitKeyNo. 2185110 
SUIT NO. 2013-DCL-3455-D 

CAMERON COUNTY, CITY OF 

BROWNSVILLE AND BROWNSVILLE 

INDEPENDENT SCHOOL DISTRICT 

§ 

§ 

vs. § 

§ 

VICTOR QUIJANO , DOING BUSINESS AS § 

TARGET PEST 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 of this setting; 

This cause came on for trial and Plaintiffs having moved the Court to dismiss from this suit any 

parties not named above, it was so ordered; and a jury being waived, the parties submitted all matters 

of controversy, both of fact and of law, to the Court without the intervention of a jury, and the Court, 

having heard the pleadings, the evidence, and the argument of counsel, is of the opinion and finds as 

follows: 

The above named Defendant(s) was the owner(s) on January 1 of each of the 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 in the amount set out below. 

IT IS THEREFORE ORDERED, ADJUDGED, and DECREED that there is due, owing, and 

unpaid to Plaintiffs the following amounts of delinquent 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 at the rates prescribed by Subchapters A and C of Chapter 33, Property 

Tax Code, which accrue hereafter on all of said taxes from date of judgment until paid. 

PROPERTY AND AMOUNTS OWED 

ACCT. NO. 0001000211265002; INV,FURN,FIXT,VEH AT 35 CUBA ST,BROWNSVILLE,TX 

CAMERON COUNTY 

Year(s) Due: 2005-2009 

CITY OF BROWNSVILLE 

Year(s) Due: 2005-2009 

Suit No. 2013-DCL-3455-D Page 1 

$481.14 

$426.34 

Suit Key Noi 'g 151 
,/.' 

BROWNSVILLE INDEPENDENT SCHOOL DISTRICT 

Year(s) Due: 2005-2009 $819.31 

TOTAL DUE: $1,726.79 

All of the property described above was, at the time that taxes were assessed, located within the 

territorial boundaries of the Plaintiffs, and the taxes were imposed in Cameron County, Texas. 

IT IS FURTHER ORDERED, ADruDGED AND DECREED that Plaintiffs recover(s) of and 

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 of Chapter 33, Property Tax Code, which accrue hereafter on all of 

said taxes from date of judgment until paid, for which let execution issue. 

All relief prayed for in any of the 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 Bar No. 24058260 

monica.solis@lgbs.com 

Attorney for: Plaintiffs 

Suit No. 2013-DCL-3455-D 

FIL[J ~'CLOCKill AURORA DE LA GARZA, CLERK 

DEC 0 I 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 of the tangible personal property the person owns that is held or 

used for the production of income if that 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 property for the 

production of income, and, for the purposes of Subsection (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 motor vehicle owned 

by the individual that is used in the course of the individual's occupation or 

profession and is also used for personal activities of the owner that do not 

involve the production of income. 

(b) In this section, "motor vehicle" means a passenger car or light truck 

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 unit to 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 inventory for taxation. In conjunction with the 

establishment of the procedures, the chief appraiser shall: 

(1) establish, publish, and adhere to one procedure for the 

determination of the quantity of property held in inventory without regard to 

the kind, nature, or character of the property comprising the inventory; and 

(2) apply the same enforcement, verification, and audit 

procedures, techniques, and criteria to the discovery, physical examination, or 
quantification of all inventories without regard to the kind, nature, or character 

of the property comprising the inventory. 

(c) In appraising an inventory, the chief appraiser shall use the 

information obtained pursuant to Subsection (b) of this section and shall apply 

generally accepted appraisal techniques in computing the market value as 

defined in Subsection (a) of this 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) If real 

property is appraised by a method that takes into account the value of 

furniture, fixtures, and equipment in or on the real property, the furniture, 

fixtures, and equipment shall not be subject to additional appraisal or taxation 

as personal property. 

(b) In determining the market value of the real property appraised on 

the basis of rental income, the chief appraiser may not separately appraise or 

take into account any personal property valued as a portion of the income of 

the real property, and the market value of the real property must include the 

combined value of the 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 

render for taxation all tangible personal property used for the production of 

income that the person owns or that the person manages and controls as a 

fiduciary on January 1. A rendition statement shall contain: (1) the name and 

address of the property owner; (2) a description of the property by type or 
category; (3) if the property is inventory, a description of each type of inventory 

and a general estimate of the quantity of each type of inventory; (4) the physical 

location or taxable situs of the property; and (5) the property owner's good 

faith estimate of the market value of the property or, at the option of the 

property owner, the historical cost when new and the year of acquisition of the 

property. 
APPENDIX 3 

LETTER FROM APPELLANT TO COURT 
AURORA DE LA GARZA 

CLERK OF THE DISTICT COURTS 

OF CAMERON COUNTY, TEXAS 

974 E HARRISON 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 motor vehicle 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 of value 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, they just 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 of that business no vehicles or 

equipment, I don't have anything of value, the only thing I have is my home which I am paying my taxes 

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 if being out of business since 2008, this people continue taxing you, it is sad and 

waste of money from us tax payers that they don't even check with the State Comptroller if businesses 

e end of this 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 OF TEXAS 

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 of December 25, 2009. 

If you should have any questions, please do not hesitate to call our office at (956)542-8426. 

oUAlonzo Vidal 

Enforcement Officer 

Brownsville Enforcement Office - 2H25 

an equal opportunity employer 

15 
APPENDIX 5 

CERTIFY LETTER OF SUBCONTRACTOR 
July 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 - -· "' ~ My Com · · s "'-''i·· .. ,, • .,.- m1ss1on Exp 1·res ,,, '" ' '"' S I • ''"""''' ep ember 21, 2017 

'''""''''