David C. Goad v. the County of Guadalupe, Texas

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AT SAN ANT&NJtJ. \'{j:.i.': No. 04-14-00497-CV 20I5K/IRI3 AN 10: U7

IN THE

-!"'THF. H^ffLE.CL!-;>--r FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

DAVID CARL GOAD Appellant.

THE COUNTY OF GUADALUPE, TEXAS,

Appelle.

APPELLANT'S BRIEF II

EXHIBITS

HEREIN, please find Exhibits for Appellant, David Goad's Brief II

Exhibit # / Letter Description A Photograph ofAircraft fenced offfrom Runway B October 10, 2008, Transcript ofJudge Nowak, Case No, SA08CV0674

c February 27, 2009, Order by Judge Biery, Case No. SA08CV0674 D Citation served on David Goad, Case No. 12-1923-CV

5 .....SETTING NOTICE 6 Letter from Debra Crow, District Clerk, Guadalupe County 7A Letter hand delivered to Judge Old 7B Email to Lynn Bothe and response 7C Letter to Judge Old, from David Goad 8 FIRST AMENDED COMPLAINT against Jamie Osborne 9 LOCAL COURT RULES for Guadalupe County 10 Affidavit of Jamie Osborne 11 Envelope sent to David Goad on January 14, 2008 12 Contents of 11 above 13 David Goad's response to contents in 11 above 14 Letter sent to Guadalupe County Tax Office 15 Letter sent to Guadalupe County Tax Office 16....' Email from David Goad to Jamie Osborne I7 Email back and forth, David Goad to/from Jamie Osborne

I8 Information gained from David Goad's FOIA request (open records). 19 David Goad's Notice of Protest

20 Agreement between Guadalupe County and Natalie Goad 21 AGREED RECORD OF SEPTEMBER 10, 2014 HEARING

Certificate of Service

I certify that a true copy of this EXHIBITS was served in accordance with rule 9.5 of the Texas Rules of Appellate Procedure on each party or that party's lead counsel on March 12, 2015 as follows: McCreary, Veselka, Bragg & Allen, P.C. Mathew Tepper, (bar no. 24029008) 700 Jeffrey Way., Suite 100 Round Rock, Texas 78665 U.S. Mail David Goad

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Q&/-J.0J z&o %{/*«*,, *-<? 1 For the defendants, what's the purpose of the fence?

2 MR. HOLLAND: Security. I would have witnesses come 3 forward to say that they've driven animals off of that runway. 4 And when a plane is landing, it's a very dangerous situation. 5 The other purpose of the fence is it's a legal fence.

6 It was by judgment, by vote of the members and --7 THE COURT: It sure sounds controversial.

8 MR. GOAD: It may be controversial, Your Honor, but a 9 majority voted for it. There was a judgment. But, more 10 importantly, plaintiff doesn't have standing. He's not a 11 member of the association. He's not a platted part of the 12 subdivision. He's not part of the platted subdivision so he 13 doesn't have standing.

14 THE COURT: Well, of course, my job is I'm going to 15 have to decide, you know, legally whether there are any claims. 16 Because today we're just talking about preliminary injunction 17 as to the 1983 claim, whether there is a likelihood of success

18 on the merits. That's all we're talking about today. And 19 that's going to be a strict legal analysis. 20 Now, regardless of what I decide on that, there's a

21 RICO claim that's going to survive today. I count my blessings 22 that in almost 20 years on the bench I haven't had to deal too 23 much with RICO claims. But it looks like we're going to have 24 to deal with one in this case. And that's going to be 25 expensive for everyone. And Mr. Goad is representing himself.

CHRIS POAGE, RMR, CRR United States Court Reporter fcA /J g*hift $

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION to DAVID GOAD, § feb «raw I § Plaintiff, § § § TOMMY ANDERSON; § DAVECAFFEY; § ROBERT DELONG; LEO GATES; CIVIL ACTION NO. DARRELL GODFREDSON; FRED HALL; SA-08-CV-0674FB(NN) JIMHOHLT; MICHAEL MEEKS; TERRY O'MAHONEY; TONY OTTO; LONNIE PENCE; A. PARKER WOOD; RICHARD WILFONG; GUADALUPE COUNTY; GENE MAYES, § Guadalupe Comity Pet 4 Constable; § SHERIFFARNOLD ZWICKE, and § RONALD PATTON, § § Defendants.

ORDER DENYING SECOND APPLICATION FOR TEMPORARY RESTRAINING ORDER

Thisorderaddresses plaintiffDavid Goad'ssecond application for a temporary restraining order.' hi the application, Mr. Goad sought an order enjoining defendant Guadalupe County, defendant SheriffArnoldZwicke, andothers acting onthesedefendants' behalf,fromarresting Mr. Goad and others without theapproval ofthis Court and toenjoin defendants from further abuse of

".* I* 'Docket entry #102. E*M# C 6*3

the judicial process. In his application, Mr. Goad stated that Sheriff Zwicke sought to execute a warrant for his arrest, already having sent deputies to his home, Mr. Goad asserted bis witnesses in this case are being harassed and intimidatedto prevent them from testifying on his behalf. Mr. Goad stated that the husband of one of his witnesses was arrested after the wife provided a swom declaration supporting Mr. Goad's application for apreliminary injunction.2 Mr. Goad also stated

that DorothyGolding—the original developer ofZuehl Airfield, Mr. Goad's primarywitness for the hearing on the application for preliminary injunction—had been incarcerated again. Mr. Goad

explained that since he filed this lawsuit, the defendants sued him instate court over the same issues disputed in this lawsuit. Mr. Goad asserted that he fears physical retaliation for pursuing his lawsuit.

To obtain a temporaryrestraining order, aplaintiffmust show (1)a substantial likelihood of success onthe merits; (2) a substantial threat that plaintiffwill suffer irreparable injury if the relief isnot granted; (3) that the threatened injury outweighs any damage that the injunction might cause the defendant; and (4) that the injunction will not disserve the public interest. 3 Apreliminary injunction isanextraordinaryremedy, granted only if the plaintiffhas clearly carried the burden of persuasion on all four requirements.4

2See docket entry # 7, exh. H (declaring that certain defendants inthis case threatened that sheand herhusband would encounter difficulty if they voted against themin property owners association business).

3Karaha Bodas Co., v. Perusahaan Pertambangan Minyak Dan Gas Bumi Negara, 335 F.3d 357,363 (5th Cir. 2003).

AKaraha Bodas Co., 335F.3dat 363.

"Since the beginning of this country's history, Congress has, subject to few exceptions, manifested adesire to permit state courts to try state cases free from interference by federal courts."5 Section 2283 of title 28 expressly prohibits federal courts from "granting] an injunction to stay proceedings inaState court except as expressly authorized byAct ofCongress, orwhere necessary in aid ofits jurisdiction, orto protect oreffectuate its judgments."6 Courts have determined that an "arrest" constitutes a"proceeding" for the purpose ofapplying this statute.7 Ordinarily, a federal court will not"enjoin state officers from instituting criminal actions... [because state officers] are charged with the duty ofprosecuting offenders against the laws of thestate, and must decide when and how this istobedone."8 "The accused should first setupand relyupon hisdefense inthe state courts... unless itplainly appears that this coursewould not afford adequate protection."9 Although section 1983 ofTitle 42 isan exception to the anti-injunction statute,10 aplaintiffseeking injunctive reliefmust still"demonstrate thathewillsuffer irreparable injury if thefederal court stays itshand, and... that he does not have an adequate remedy atlaw inthe state courts."" Mr. Goad has not

lounger v. Harris, 401 U.S. 37,43 (1971). 628U.S.C.§2283.

''See HartsvUle Theatres v. Fox, 324 F. Supp. 258,262 (D.C.S.C. 1971) ("Anarrest, it wouldseem, satisfiesthis 'comprehensive' definition of'proceedings.").

*Younger v. Harris, 401 U.S. 37,45 (1971). See Trainor v. Hernandez, 431 U.S. 434, 441 (1977) ("[B]asic concerns of federalism... counsel againstinterference byfederal courts, through injunctions orotherwise, with legitimate state functions, particularly with the operation ofstate courts.").

9Id. (citation & quotation marks omitted).

wSeeMitchum v. Foster, 407 U.S. 225,243 (1972) (explaining why section 1983 is an "expressly authorized" exception ofto the anti-injunction law).

"Duke v. Texas, All F.2d 244,248 (5th Cir. 1973). shown that he faces irreparable harm. Guadalupe County and theSheriffstated that Mr. Goad was arrested and released on bond the following day. The state-court criminal procedures provide a mechanism for an accused to defend himselfandto expunge an improper arrest. Mr.Goad cannot show hehas noadequate remedy atlaw because the Texas state courts provide a criminal defendant with remedies for a wrongful arrest. Without a showing of irreparable injury and an inadequate remedy, this Courtcannotenjointhe state court.

That said, Mr. Goad's allegations are serious. Regardless of who actually arrested Mr. Goad12 orwho prosecutes the charges against Mr. Goad,13 the arrest and the charges originated from defendant Guadalupe County. Ifthedefendants are using arrests andcriminal charges tointimidate or harass Mr, Goad or his witnesses, the defendants could face serious consequences. Witness tampering andwitness retaUation are federal offenses. "Whoever knowingly uses intimidation, threatens, or corruptly persuades another person, or attempts to do so .... with intent to ... influence, delay, orprevent thetestimony ofany person inanofficial proceeding [like this lawsuit] ... shall be fined... orimprisoned not more than 20 years, orboth."14

Whoever knowingly engages in any conduct and thereby causes bodily injury to anotherperson ordamages the tangible propertyofanother person, orthreatens todo so, with intent to retaliate against any person for... theattendance of a witness or party at anofficial proceeding, or any testimony given or anyrecord, document, or

12Guadalupe County and thesheriffreported that theU.S. Marshal executed thecapias for Mr. Goad's arrest. Seedocket entry# 104.

"Guadalupe County and the sheriffreported that the district attorney isprosecuting the charges against Mr. Goad. See docket entry # 104. 1418U.S.C.§ 1512(b).

other object produced byawitness inanofficial proceeding... orattempts todo so, shall be fined... orimprisoned not more than 20 years, orboth.15

Efforts to impede the prosecution ofthis lawsuit by intimidating Mr. Goad orhis witaesses would likely be admissible at trial, undermine any defenses, increase Mr. Goad's damages, and result in civil sanctions. TheCourt looks to theattorneys todiscuss Mr. Goad'sallegations with theirclients and advise the defendants about the inappropriateness and consequences of interfering with the prosecution of this lawsuit.

IT IS THEREFORE ORDERED, for the reasons discussed in this order, that Mr. Goad's application for atemporary restraining order (docket entry # 102) isDENIED.

ITISFURTHER ORDERED theClerk ofCourt shall send a copyofthisOrder to thecounty judge ofGuadalupe County and the state district judges sitting inGuadalupe County.

It is so ORDERED. tr

SIGNED this ^ ~* day ofFebruary, 2009.

FRED BIERY UNITED STATES^JISTRICT JUDGE

1518U.S.C§ 1513(b).

CAUSE NO. mm-w THE COUNTY OF GUADALUPE, TEXAS IN THE DISTRICT COURT

PLAINTIFF

VS. 25th JUDICIAL DISTRICT

DAVID C. GOAD, ET AL DEFENDANT GUADALUPE COUNTY, TEXAS

CITATION IN A DELINQUENT TAX SUIT DEFENDANT TO BE SERVED: David C. Goad aka David Goad (No Personal Liability) 1154Rivertree Drive, New Braunfels, Comal County, Texas 78130-2425 Phone Number: (830)221-5905 __ *************************************************************************************** RETURN OF CITATION IN A DELINQUENT TAX SUIT \

CAME TO HAND on the fit day of \nbhh 20]>, at lift f o'clock A4^PNL>d Texas, by delivering to the within named defendant, IN PERSON, a tnferCopy of executed in Comal County. this Citation, at the followingtime and place, to-wit:

NAME OF DEFENDANT to whom citation delivered:

Return of Citation by Personal Service Date Delivered Time Delivered - AM/PM , Wh€te Delivered

//-m~M^ BOB HOLDER Sheriff off Comal County SHERIFF, COMAL COUNTY, TEXAS

l-V A^ (JF'yb) DEPUTY FEE for Service $

lJ // RESPOMDfiNrS COPY £*&# D

THE STATE OF TEXAS

CAUSE NUMBER

PLAINTIFF IS:TheCountyof Guadalupe, Texas, collecting propertytaxes for itselfand for Marion Independent School District

DATE OF FILING OF PLAINTIFF'S LATEST PETITION ("DATE¹ ,;i»ptor,n aTfo)IQ. COURT: 25thJudicial District Court of Guadalupe County, Texas at theCourthouse of saidCounty located in Seguin, Texas ("COURT")

TO DEFENDANT: David C. Goad aka David Goad (No Personal Liability) 1154 Rivertree Drive, New Braunfels, Comal County, Texas 78130-2425 This defendant owns or has an interest in Tract 1 described on attached Schedule A. Defendant, GREETINGS: You have been sued. You may employ an attorney. If you or your attorney do naf file a written answer with the clerk who issued this citation by 10:00 a.m. on the Monday next following the expiration/of twenty days after you wejfe served this citation, a default judgment may betaken against you. YOU ARE HEREBY COMMANDED to appear and answer before the Honorable COPRJLat or bejate-H>!rj& a.m. ofthe Monday next after the expiration of20 days from the date ofservice ofthis Citation, then and thereto answer the petition ofthe PLAINTIFF named in Plaintiffs Petition, filed in said COURT on the DATE against the above named DEFENDANT, said suit being numbered on the docket of said COURT as the CAUSE NUMBER shown above, the nature/Of which demand is a suit to collect delinquent property taxes on the PROPERTY(S), described on attached Schedule A. All Defendants in this suit are named on attached Schedule A. The total amount of delinquent taxes due PLAINTIFF, exclusive of interest^ penalties and costs, is the sum of $830.72, on said PROPERTY(S) being more particularly described on attached Schedule a/tHE TOTAL AMOUNT OF DELINQUENT TAXES, PENALTY, AND INTEREST DUE ON THE PROPERTY(S) AS OF THiS DATE THAT MUST BE PAID IS $1,372.42. The names of all taxing units which assess and collect taxes on jgaid PROPERTY(S), not made parties to this lawsuit are INTERVENORS. PLAINTIFF and all other taxing units wh«f may set up their tax claims herein seek recovery from DEFENDANTS of delinquent ad valorem taxeson the PROPERTY(S), and in addition to the delinquent taxes, all accrued statutory penalties and interest, costs, and attorney's fees allowed by law thereon up to and including the day of judgment herein, and the establishment and foreclosure of tax liens securing the payment of the same as provided by law. However, PLAINTIFF does not seek a personal judgment foranyof theamounts dueagainstDEFENDANTS designated "No Personal Liability". All parties to this suit, including PLAINTIFF AND DEFENDANTS, shall take notice that claims not only for any taxes which were delinquent on said PROPERTY(S) at the timethis suit was filed, but all taxes becoming delinquent thereon at any time thereafter up to the day of judgment, including all accrued statutory penalties and interest, costs, and attorney's fees allowed by law thereon, may, upon request therefore, be recovered herein withojn further citation or notice to any parties herein, andall saidparties shall take notice of and plead and answerto all claims and pleadings now on file and which may hereafter be filed in this cause by all other parties hereto, and by all of those taxing units aboy/named, who may intervene herein and set up their respective tax claims against said PROPERTY(S). The officer executing this return shall promptly serve the same according to the requirements of law and the mandates hereof and make due return as the law directs.

Issued and givenundernwhand a/w seal ofsaid COURT at Seguin, Texas, this the ^itf^rfAltemhM.aoEL. McCREARY, VESELKA, BRAGG & ALLEN, P.C. ATTORNEYS FOR PLAINTIFF P.O. Box 537 Seguin, Texas 78156-0537 (830) 379-5600 Fax: (830) 379-2202

(Clerk/Deputy Clerk)

SCHEDULE A

PLAINTIFFIS: TheCounty of Guadalupe, Texas, collecting property taxesfor itselfand for Marion Independent School District

DEFENDANTS ARE: David C. Goad aka David Goad (No Personal Liability) (Interest in Tract 1) Kristin G. Goad aka Kristin Goad (No Personal Liability) (Interest in Tract 1) Natalie H. Goad aka Natalie Goad (No Personal Liability) (Interest in Tract 1)

PLAINTIFF seeks a persona! judgmentfor all amounts due against DEFENDANTS designated "Personal Liability". PLAINTIFF doesnot seek a personal judgment for any of the amounts due against DEFENDANTS designated "No Personal Liability". PLAINTIFF seeks foreclosure of the tax liens on the PROPERTY as to all the DEFENDANTS.

PROPERTY AND AMOUNTS DUE:

Tract: 1 Account Number: R146794/2G0134000001105000 Property Description: 1.00 Acre, more or less, out of Abstract 134 of the Jose Flores Survey, Guadalupe County, Texas Approximate Property Address: Windsock Deed Reference: Volume 2537, Page 681 Assessed Name: GOAD DAVID C CUSTODIAN FOR KRISTIN G & NATALIE H $1,372.42 Due to The County of Guadalupe, Texas For Tax Years: 2008-2011 $1,372.42 TOTAL DUE (09/2012)

TOTAL AMOUNTS DUE: $1,372.42 Due to The County of Guadalupe, Texas $175.00 Title Research Fee $1,547.42 TOTAL DUE (09/2012) $1,557.41 TOTAL DUE (10/2012)

IN ADDITION TO THE DELINQUENT TAXES AND TITLE RESEARCH FEES, THERE ARE COURT COSTS WHICH MUST BE PATD. CONTACT THE DISTRICT CLERK'S OFFICE AT (830) 303-4188 X241 FOR THE AMOUNT OF COURT COSTS THAT MUST BE PAID BEFORE THIS LAWSUIT CAN BE DISMISSED.

IF THIS LAWSUIT HAS NOT BEEN DISMISSED, DELINQUENT TAXES FOR SUBSEQUENT TAX YEARS ON THIS PROPERTY ARE AUTOMATICALLY INCLUDED IN THIS LAWSUIT ON THE FTRST DAY OF DELINQUENCY AND INCUR STATUTORY PENALTIES, INTEREST AND ATTORNEY FEES AUTHORIZED BY THE PROPERTY TAX CODE.

CAUSE NO. 12-1923-CV

THE COUNTY OF GUADALUPE § IN THE DISTRICT COURT TEXAS § § Plaintiff, § v. § 25th JUDICIAL DISTRICT § DAVID C. GOAD, ET AL § § Defendant. § GUADALUPE GL COUNTY, TEXAS

SETTING NOTICE CE

Defendant, David Goad asks the Clerk of the Court to set all hearing(s) after first confirming dates in which both plaintiff and defendant available. December 5, 2012 Respectfully submitted,

DAVID GOAD, Defendant pro se 1154 Rivertree Drive New Braunfels, Texas 78130 830-515-205

CERTIFICATE OF SERVICE

The undersigned certifies that on December 5, 2012, the foregoing Setting Notice was served on all parties of record as set out herein below:

McCreary, Veselka, Bragg & Allen, PC. Attorneys for Plaintiff P.O. box 537 Seguin, Tx 78156-0537 U.S. Mail

David Goad

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101 E. Court, Suite 308 Seguin, Texas 78155 ^ Phone: (830) 303-8873 Fax:(830)379-1943

Debra Crow, District Clerk VISA/MASTERCARD

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David Goad 1154 Rivertree Drive New Braunfels, Texas 78130

March 5, 2014 Re: Jury Fees Mr. Goad,

In regards to your jury fee return request for cause numbers 12-1923-CV and 08-1872-CV, this office is unable to approve that request. Please referto LGC 51.604. In addition, there is no record of a jury demand denial in either case.

Thank you, .it*"1"'///.

DEBRA CROW Guadalupe.District C[erk ;0! • —-

'• 2 = BnM Deputy \o'">—>&V

THIS NOTICE WAS HAND DELIVERED TO JUDGE OLD III OFFICE

Dear Judge Old III,

Please be advised that I am hand delivering the DEFENDANT'S MOTION FOR CONTINUANCE (copy) due to past irregularities with Court Clerks.

1also ask that you review the entire file. 1 have steadfastly been denied the procedures set fourth in the "LOCAL RULES OF PRACTICE AND PROCEDURES" Rule 1. Settings 1.1 "No Court will notify a party of a setting except in the case of a request for a setting by a pro se litigant."

This Notice has been forwarded to opposing council as per "CERTIFICATE OF SERVICE" attached to the aforementioned DEFENDANT'S MOTION FOR CONTINUANCE.

David Goad

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&*** "7* RE: 12-1923-CV

Subject: RE: 12-1923-CV From: Lynn Bothe <lynnb@co.guadalupe.tx.us> Date: 3/3/2014 8:36 AM To: "1983remedies@gmail.com" <1983remedies@gmail.com>

Dudge Old denied your motion for continuance.

Lynn Bothe 25th Judicial District Court Administrator

Original Message From: 19S3remedies§gmai.l ..con] [jnii]:t5.;JJS3re§eclies§gm3il.:.ccm] Sent: Monday, March 03, 2014 8:33 AM To: Lynn Bothe Subject: 12-1923-CV

Hola, A trial was set for this morning. I was expecting a call last week regarding a motion for continuance, however, I have heard nothing. Please inform the court (if the motion has not been signed) that my medical issues persist requiring me to take pain medication at 3:30a.m, and again at 7:15 a.m. this morning. I am unable to come into court this morning.

Thank Yoo David Goad

" * lofl fyitf Z*

David Goad 1154 Rivertree Drive New Braunfels, Texas 78130

March 31, 2014

William D. Old III., District Judge. 101 E. Court Street., Rm. 203 Seguin, Texas 78155

Re: 12-1923-CV Hola Judge Old III, Ms. Bothe informed methat you denied my Motion for Continuance at the last hearing.

To this date I have not received the order of denial nor any other orders or rulings. I must say this has been an issue in other cases within Guadalupe County Courts.

Please find enclosed an envelope with a stamp attached addressed to myself. I ask that you be kind enough to forward to me your order of denial and any other issues you may have signed at that last hearing.

David Goad

Copy mailed to: McCreary, Veselka, Bragg & Allen, PC. P.O. Box 537 Seguin, Texas 78156-0537

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CAUSE NO. JSC4-4995

DAVID GOAD § ^ IN THE JUSTICE COURT Plaintiff, § r„Tm v § PRECINCT NO. FOUR § JAMIE OSBORNE § Defendant. § GUADALUPE COUNTV, TEXAS

FIRST AMENDED COMPLAINT

Plaintiff, David Goad, files this First Amended Complaint and will show the Court the following:

1. Plaintiff, David Goad hereinafter known as "P-DG" resides at: 1154 Rivertree Drive. New Braunfels, Texas 78130.

2. Defendant, Jamie Osborne, hereinafter known as "D-JO" whose work address isat: 3000 North Austin Street, Sequin, Texas 78155. She is being sued individually. This suit does

not include Guadalupe County.

3. The real property in question is a one acre parcel purchased under the Texas Gift to Minors Act inSeptember of2007. Described as: Aone acre tract ofland situated in Guadalupe County, Texas out ofthe Jose Flores Survey no. 63. Abstract no. 134. being part ofone ofthose tracts conveyed to Dorothy Buffington Golding and recorded in Volume 483. page 694 of the deed records ofGuadalupe County, Texas.

4.Natalie Goad is the daughter of David Goad; she was a minor by statute at the time of the allegations set fourth herein.

5. All exhibit's submitted (attached hereto), or submitted in future pleadings are incorporated into the pleading, motion, or document of which they are attached are incorporated ^| into and made a part of by reference. FILED DA^P"^iiSicr#*SEGUlN ^Secoukty.texas -l •*

FACTS AND ALLEGATIONS

6. P-DG alleges that D-JO has acted in a manor, and/or commanded others (conspired) in violation of clearly established federal law, and Texas State law to violate P-DG's federally protected rights and take his property

7. P-DG alleges: D-JO committed fraud, conspiracy, intentional or deliberate misconduct which subjected P-DG to the deprivation of his federally protected rights. Some of the acts were discretionary, however, others were not, and in no case, conducted in good faith.

8. P-DG alleges D-JO destroyed or otherwise, with or without conspiracy, "sanitized" the files in which all documents supporting the allegations set fourth in this complaint could be found. When "sanitized'' is noted at the end or within a sentence, it means that document has been removed from D-JO's records and all the tax records of Guadalupe County.

9. D-JO failed to respond to her own Notice of Protest sent to P-DG on January 14, 2008 "sanitized'" Furthermore, D-JO failed to address P-DG's response to said notice "sanitized""

10. D-JO failed to provide P-DG a hearing to protest his taxes after she was noticed on August 3, 2009 "sanitized;" August 4, 2009 "sanitized;" and on May 31, 2013 "sanitized."" Thus denying his due process rights.

¹¹. On April 15, 2014, P-DG meet with D-JO at her office to review the documents within the file regarding the subject property based upon an FOIA request See Exhibit "A". Not one notice from D-JO or P-DG was found or noted in the documents provided to P-DG that day "sanitized.""

12. On April 15, 2014, P-DG explained to D-JO that the property in question was fenced-out in 2008 from all public access and therefore its value went to zero, as the property was landlocked and fenced out by a combination of public officials and others. It was clear during our conversation that D-JO was aware of the federal litigation (RICO) P-DG had brought against her friends and others.

13. OnApril 15, 2014, P-DG explained to D-JO that she needed to reevaluate (appraise) the property to reflect the facts due to ongoing litigation over the unpaid taxes. As a result of no action on the part of D-JO, a judgment was issued reflecting false/fraudulent tax evolutions against P-DG and his daughter Natalie. At that time Natalie was 20 years old. A young woman who graduated at 15 years old and at age 19 she graduated from UT Austin with a double major. A young woman that now has a judgment against her because of D-JO.

14. On April 15, 2014, at the request of D-JO, P-DG signed a "Requestfor Field Inspection" See Exhibit "B" in order that D-JO may enter upon said property for evolution purposes. D-JO did not submit her findings, if any, to alter the Tax case.

15. On April 15, 2014, P-DG provided to D-JO a photograph depicting an aircraft on the subject property with a fence across it. See Exhibit "CI & C2," C2 was created by hand (exact copy of text) due to my email program making it unable to print with the text included (to large).

16. D-JO and others valued the property at the following:

a. $12,500.00 before and after the property had no access (fenced out).

b. Increased to $21,713.00 for 2013.

c. Decreased to $10,956.00 (noted on tax roles) for 2014, however, when P-DG was at D-JO's office on April 15, 2014, the value was noted at under $9,000.00 for 2014? We must take notice that property values all across Texas have risen well in the last year!

JAMIE OSBORNE HAS NO IMMUNITY WHATSOEVER

17. Government officials performing discretionary functions generally are granted a qualified immunity and "shielded from liability for civil damages insofar as their conduct does

j -not violate clearly established statutory or constitutional rights of which a reasonable person would have known. "Harlow v. Fitzgerald U.S. 800, 818,102 S.Ct. 2727, 73 L.Ed.2d 396 (1982).

18. Government officials acting within their discretionary authority are immune from civil damages if their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known. "Evett v. Detntff, 330 F.3d 681, 687 (5 Cir. 2003).

19. To determine whether an official is entitled to qualified immunity, two questions must be answered: (1) whether the plaintiff has alleged a violation of a clearly established constitutional right; and (2) if so, was the defendant's conduct objectively unreasonable in light of clearly established law at the time of the incident. See Hare v. City ofCorinth, 135 F.3d 320, 325 (5th Cir 1998) (citing Colston v. Barnhart (5th Cir. 1997).

20. To overcome a claim of qualified immunity, a plaintiff must establish that the right an official is alleged to have violated was "clearly established."' i.e., sufficiently clearly defined that " a reasonable official would understand that what he is doing violates that right." Anderson v. Creighton, 483 U.S. 635,640 (1987).

STATE LAW DOES NOT TRUMP FEDERAL LAW

21. In Howlet v. Rose 496 U.S. 356, 375 (1990). "state ("including Texas," added by P-DG) law may not immunize § 1983 defendants Congress has subjected to liability." Therefore, any failure of P-DG to exhaust remedies under state law, immunities whether governmental or official (state law), or any other state rule or law is void in this case, except of course, court room procedures. The only reason any attorney would attempt to inject Texas State law to gain immunity inthis case, would be to extract attorney fees from the hard working Guadalupe County tax payers. P-DG reserves to later move for sanctions against any attorney who would play/played such a game.

22. The United States Supreme Court in Gomez v. Toledo 466 U.S. 635 (1980). found that §1983 itselfrequires only two essential allegations: "Bythe plain terms of §1983, two-and-only two allegations are required in order to state a cause of action under that statute, First, the plaintiff must allege that some person hasdeprived him of a federal right. Second, he must allege that the person who deprived him of that right acted undercolor of state or territorial law." and now in Ashcroft v. Iqbal, 129 S. Ct 1937 (2009) §1983 complaints now must contain factual allegations constituting a plausible claim.;

23. The United States Supreme Court has established that pro se complaints are subject to "less stringent standards than formal pleadings drafted by lawyers" and should be liberally construed in the plaintiffs favor, see Erickson v. Pardus, 127 S. Ct. 2197, 2200 (2007).

24. The United States Supreme Court, in Felder v. Casey 487 U.S. 131,138 (1988), stated in the same breath that while "[n]o one disputes the general and unassailable proposition.. .that States may establish the rules of procedure governing litigation in their own courts[,]... by the same token, however, where state courts entertain a federally created cause of action. " the federal right cannot be defeated by the forms of local practice."(quoting Brown v. Western Ry„ 338 U.S. 294, 296 (1949).

CONCLUSION

25. D-JO, acts under the color of state law in her acts and in concert with the same or similar acts by many officials from within Guadalupe County (Judge Steel, Judge Kirkendall. Judge Old, Judge Sachtleben (aka The Black Robe Syndicate of Texas), Guadalupe County

District Attorney , Guadalupe County District Clerk, Debi Crow, Guadalupe County Sherriff Zwicke, the altering ("sanitizing") of officials records by court clerks, DA, Sherriff, court

reporters etc, etc. and many others) which have deprived P-DG ofproperty, due process rights, and much, much more forthe last seven years. These noted issues were all brought on as a result

of P-DG filing litigation under RICO against Guadalupe County Officials.

REQUEST JUDICIAL NOTICE

26. The following cases will prove that powerful Officials from Guadalupe County can trump-up false criminal charges, have an innocent person put injail, tortured, and dojust about anything they want to do to silence P-DG. It is for this reason that P-DG requests judicial notice of said cases as a clear pattern exists. Furthermore, the jury trial in this case will explore the details of these cases to link D-JO conspiracy with others (similar acts) who have the same goal. Please take note of the following cases:

a. Goad v. Anderson SA08CA0674

b. Zuehl v. Goad 08-1872-CV

c. Goad v. Crow SA11CA1056-OG

d. State of Texas v. Goad 09-0190-CR

e. State of Texas v. Goad C2008-1461C

f. Zuehl v. Goad 2010-CI 12496, appeal 04-11-00293-CV

g. Goad v. Wyatt JSC2-1000

27. Witnesses and evidence to be presented at the upcoming hearing on September 10, 2014, will provide more than ample facts to bring an indictment against D-JO, and others, from even the most discriminating grand jurors.

LEGAL FRAMEWORK AND STATEMENTS OF FACT

Violations of U.S. Constitution, 4th and 14th Amendment, Under Title 42 of the

United States Code. §1983. and 1985.

28. "Amongthe civil rights intended to be protected from discriminatory state action by the Fourteenth Amendment are the rights to acquire, enjoy, own and dispose of property. Equality in the enjoyment of property rights was regarded by the framers of the Fourteenth Amendment as an essential precondition to the realization of other basic civil rights and liberties which the Amendment was intended to guarantee. Conroy v. Manos,

679 S.W.2d 124,133 (Tex.App.-5,h Dist., 1984). Rights in property have long been considered basic civil rights which cannot be taken away without just cause and due

process.

29. Due Process is that whichcomports with the deepest notions of what is fair and right and just in law. U.S. Supreme Court Center, see http://supreme.justia.com/constitution/amendment-05/16-due-process.html Due process is violated if a practice or rule "offends some principle of justice so rooted in the traditions and conscience of our people as to be ranked as fundamental. Snyder v. Massachusetts, 291 U.S. 97, 105 (1934). Procedural due process requires the government to adhere to its own rules. United States ex rel. Accardi v. Shaughnessy, 347 U.S. 260, 268, 74 S.Ct. 499, 503, 98 L.Ed. 681 (1954) and recognize that the constitutional right to be heard is a basic aspect of the duty of government to follow a fair process of decision making when it acts to deprive a person of his possessions. Fuentes v. Shevin, 407 U.S. 67, 80, 92 S.Ct. 1983,1994,32 L.Ed.2d 556 (1972).

30. The over assessing of said property was intended to facilitate the taking of that property from the plaintiff. Among the civil rights intended to be protected from discriminatory

state action by the Fourteenth Amendment are the rights to acquire, enjoy, own and dispose of property. Equality inthe enjoyment of property rights was regarded by the framers ofthe Fourteenth Amendment as an essential precondition to the realization of other basic civil rights

and liberties which the Amendment was intended to guarantee. Conroy v. Manos, 679 S.W.2d 124 (Tex.App.-5th Dist., 1984).Rights in property have long been considered basic civil rights which cannot be taken away without just cause and due process.

31. A cause of action for a violation of the 14th Amendment can come under Title 42 of the U.S. Code, which reads in part:

Sec. 1983. Civil action for deprivation of rights "Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress...42 U.S.C.A. § 1983 (West 1981).

Sec. 1985. Conspiracy to interfere with civil rights "If two or more persons in any State or Territory conspire or go in disguise on the highway or on the premises of another, for the purpose of depriving, either directly or indirectly, any person or class of persons of the equal protection of the laws, or of equal privileges and immunities under the laws; or for the purpose of preventing or hindering the constituted authorities of any State or Territory from giving or securing to all persons within such State or Territory the equal protection of the laws... or to injure any citizen in person or property on account of such support or advocacy; in any case of conspiracy set forth in this section, if one or more persons engaged therein do, or cause to be done, any act in furtherance of the object of such conspiracy, whereby another is injured in his person or property, or deprived of having and exercising any right or privilege of a citizen of the United States, the party so injured or deprived may have an action for the recovery of damages occasioned by such injury or deprivation, against any one or more of the conspirators. 42 U.S.C.A. § 1985 (West 1981).

-8

32. Statejudges and state courts are repositories of state power, and state court actionmay in some cases amount to a deprivation by a state of rights guaranteed by Fourteenth Amendment to the federal constitution. Gay v. Heller, 252 F.2d 313 (C.A.5.Fla., 1958). Congress enacted § 1983 to provide an independent avenue for protection of federal constitutional rights. Conroy v. Manos, fn. 1. The remedy was considered necessary because state courts were being used to harass and injure individuals, either because the state courts were powerless to stop deprivations or were in league with those who were bent upon abrogation of federally protected rights. Pulliam v. Allen, 466 U.S. 522,104 S.Ct. 1970,1980,80 L.Ed.2d 565 (1984)

REQUESTS

PLAINTIFF THEREFORE respectfully requests that the Court enter a judgment including, but not limited to:

The costs of actual losses and the maximum amount of damages allowed by the court in which this issue is finally decided, currently not less than $10,000.00.

All attorney's fees and court costs for bringing this Complaint;

All other relief in law and in equity as may be proven at trail; and

Plaintiff requests a jury trial.

Res/fectfulH submitted,

David Goad, Plaintiffpro se 1154 Rivertree Drive New Braunfels, Texas 78130 (830)515-2052

DAVID GOAD 1154 Rivertree Drive New Braunfels, Texas 78130 1983remedies@gmail.com 830-515-2052

April 1, 2014

FREEDOM OF INFORMATION ACT REQUEST

TO: The County Appraisal District for Guadalupe County josborne@guadalupead.org Sequin, Texas 78155

Dear Ms. Osborne:

Pursuant to 5 U.S.C. §522 etseq., and Tex. Gov't. Code, Sec. 552.022(a), I hereby make this request that the following be made available for inspection:

This request surrounds the property described as:

Assessed Name: Goad David Custodian for Kristin G & Natalie H Goad 1.00 Acre, more or less, out of Abstract 134 of the Jose Flores Survey, Guadalupe County, Texas.

Street: Windsock Property ID: 107520

1. This request begins after the purchase date of the current owners which would be after the purchase in mid 2007.

1. Please provide the name of the appraisers) who conducted the appraisals on said property for taxation purposes. If more than one appraiser was involved please provide a brief explanation as to the tasks each carried out.

2. Please provide the academic background, training, and appraisal history of each appraiser.

3. Please provide a copy and any licenses, certificates and other which illustrate the appraiser's professional background including, but not limited to the issuing authority and dates issued.

4 Please provide access to the originals of all hand written or typed notes, photo's, other properties used as comparables, and all data used to appraise said property. It is important that all amenities, condition of, and notation(s) (including pictures) be provided for the comparables. 5. Please provide the sources and dates gathered for all data used in process of appraising said property.

6. Please provide the legal term and the trade term to define the method in which the appraiser followed to conduct his/her evaluation for the appraisal. 7. Ifany of the requests are withheld please state the nature of the withheld document or other, and under what legal premise you assert the withholding.

You are welcome to contact me with any questions, preferably by email as listed above. In the event this information is held within a computer or even a paper file, I ask that you to provide me a date, time and location in which I can review. In the event I need copies, I will mark each page in an acceptable manner to accomplish this task after review. If any of these records do not existplease inform me.

Thank You David Goad

RECBVED $P- APR ? 5 20W GUADALUPE APPRAISAL DISTRICT ***»*^»«««! Man Oifiec WtflKaMltlaiiw Q»d'A,W»awcr S00ON. Austin SL 1101 Elbe'Ud. Dr. G««gCi!craac-CI»ir Jamie Osimmc Seguin,Tcsw781S5 Sdiem, Texas 78)54 Mrs. 'fnvic MmpJiy-Vk(>CliaJr 830.303^313 210^45.9708 ExlBH Mr. Mark.Wiisoii-SMreuny Deputy Cliict' Amiraitcr 83a.37SJ»7*CRK) }HU6S.1334fl&> Mr. Darren Duuu- Mcciljer ly-irliSlray fsuinra(cst@gu&dalupcac!.otg Mr. Loon B. Ramirez, Sr.-Mcmbcr

BEQUESTFOR FIELD INSPECTION

TheGuadalupe Appraisal District (G.AJD.) requests your consentas legal owneror authorized agentto inspec: property identification fl: . Acknowledgment below indicates that you are aware of this request for field inspection, and hereby haveauthority and grantautbority to the Guadalupe Appraisal District ChiefAppraiser or Chief Appraiser's designee to field inspect the above referenced property for the current January 1"appraisal date for the limited purpose and scope as outlined in §6.01 and §23.01 of the Texas Tax Code, Texas Constitution Article VDi, §1. and 34Texas Administrative Code, §9.3001. Please be advised that if request for inspection is granted this inspection will occur after the date indicated below.

^Consent for field inspection is granted this the / S~~day of/vC^^L 20/J. •No

re ofLegd Owt&r orAuthorized Agent-Licensed

%*>*- <Ts^- rpq<-T Phonejfuntber y~>

rmtedNtone Prmtet ofLegal Owner orAuthorizedAgent

Acknowledgment of abovenoted designation: GJLD.Representative

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<£ J& ,'7'yf Jr^^S*' H

, j s^XTrff < „ iff ^,^sr

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Goad property photo

t/fa/yal4 j oik:* „

LOCAL RULES OF PRACTICE

ORDER ADOPTING RULES OF THE

25th" 2nd 25th and 274th JUDICIAL DISTRICTS OF TEXAS

FOR GUADALUPE COUNTY

It is Ordered by the 25th, 2nd 25th and 274th Judicial District Courts of Texas that:

1. The 25th , 2nd 25th and 274th Judicial District Local Rules of Practice and

Procedure for Guadalupe County as hereinafter set out are hereby adopted subject

to the approval of the Supreme Court of Texas and the Council of Judges of the

Third Administrative Judicial Region of Texas. 2. The Clerks of the Courts in Guadalupe County shall record the Rules of Practice

and Procedure and this Order in the Minutes of the Court; 3. A copy of these rules and this order shall be furnished to the Supreme Court of

Texas, the Courts of Appeals for the 4th District of Texas and the Presiding Judge of the Third Administrative Region of Texas;

4. Each Clerk of the Courts shall deliver to each lawyer maintaining an office within

the county each Clerk serves a copy of these local rules, a copy shall further be

furnished by the Clerk to each lawyer and pro se party appearing in any civil

action in this Court. Each Clerk shall keep a current record of such delivery, the

date thereof, and make such record available for inspection. 5. These Rules of Practice and Procedure, as may hereafter be amended, shall be

construed and interpreted in addition to, and in conformity with and not as

superseding the Constitution and laws of the State of Texas, the Texas Rules of

Civil Procedure, rules adopted by the Council of Judges of the Third

Administrative Judicial Region or rules promulgated by the Supreme Court of

Texas. 6. Should any of these rules, or any part thereof, or any amendments thereto, be held

invalid for any reason, such invalidity shall not affect the validity of the other

rules or parts of rules, all of which have been separately considered and adopted. 7. These rules shall be effective on the date this Order is signed and thereafter until

amended, modified or repealed by the order of these Courts. Signed, Ordered and Effective this the /2ff- day of ftj^r, 2005

ind ~cth lna 25,n Judicial DistrictJudge

274 Judicial-District Judge Local Rules of Practice for the 25th, 2nd 25th and 274th Judicial District Courts of Texas in Guadalupe County

The dockets ofthe 25th, 2nd 25th and 274th District Courts ofGuadalupe County are to be held in accordance with schedules published annually which may be obtained from the

office of either judge or from the office of the district clerks.

Any case filed in the 25th, 2nd 25th or 274th Judicial District Courts may be heard in either Court without transfer or further order except:

1. A family case involving custody of a child, if contested temporary orders are

heard, must be set thereafter in the Court hearing said temporary orders; 2. Any motion to modify custody must be heard in the Court issuing the order to be

modified if thatCourt heard contested hearings in making the original order; 3. Any case in which judge is disqualified or recused must be heard only in the other

Court; and 4. Any othercase where the Court orders the case to a particular judge. In all proceedings in these Courts, the Texas LawyersCreed will be observed.

Civil and Family Cases 1. Settings

1.1. All hearings in contested cases must be set by written motion with order

attached and with an estimated time for the hearing. Attorneys requesting

settings are responsible for notifying opposing parties within the time

constraints of the Rule of Civil Procedure. No Court will notify a party of a

setting except in the case of a request for a setting by a pro se litigant.

1.2.0nly a court coordinator may set a case. Either the court coordinator for the

25th , the 2nd 25th or the 274th Judicial District may set cases on any of the courts' dockets, subject to the approval of the coordinator of the Court

receiving the case .

1.3. All motions for continuance must be in accordance with Articles 29.01 el seq..

C.C.P. and Rules 251 et seq., T.R.C.P. With the approval of the court

coordinator, a contested case may be set of passed by the agreement of all

counsel; however the mere filing of a motion for continuance does not mean that

the continuance will be granted, even with the agreement of all parties. Unless

released in writing by the court coordinator, counsel must appear as scheduled.

1.4. Prior to setting any cases for any hearing, counsel must call the court coordinator

to obtain available hearing dates. Counsel must then contact opposing counsel to

insure the date is agreeable to all counsel. Once a date is agreed, counsel may

CAUSE NO. JSC4-4995

DAVID GOAD, § IN THE JUSTICE COURT PLAINTIFF. §

VS. § PRECINCT NO. 4

JAMIE OSBORNE, DEFENDANT. I § GUADALUPE COUNTY, TEXAS

AFFIDAVIT OF JAMIE OSBORNE $1 STATE OFTEXAS §

COUNTY' OF GUADALUPE §

Before mc, Ihc undersigned notary, on this day personally appeared Jamie Osborne, the affiant, whoseidentity is know) to me.AfterI administered an oath, affiant testified as follows:

1. "My name is Jamie Osbonie. Iam over 18 years old. I am ofsound mind and capable of making this affidavit. The tacts stated in this affidavii arc true and correct and within my personal knowledge.

2. The Guadalupe Appraisal District (hereinafter the "Disiriei") is responsible for appraising property in Guadalupe County for ad valorem tax purposes ofeach taxing unit that imposes ad valorem taxes in the district.

3. The Disiriet is governed by ils board of directors, who arc district residenis. The District's board of directors appointed me as Chief appraiser in August of 2006. Anion" my duties as the chief appraiser is the annual preparation of appraisal records listing all property taxable inGuadalupe County and stating the appraised value ofeach. 4. The District's mission is to discover, list and appraise property as accurately, ethically and impartially as possible to estimate the market value of all property within Guadalupe County, Texas. The District must make sure that each taxpayer is given the same consideration.

Page 1 of4 1

• • "5

" _// £Mtf /o

infoniiation, and assistance as the next. The Constitution of the State of Texas, the Texas Tax. Code,and tlie Rules of die Comptroller's Officegovernthe District's operations and practicesof

its appraisers. Tlie District and its appraisers also must comport with the staudards of the Property Tax Assistance Division of the Comptroller's Office and the Uniform Standards of Hi Professional Appraisal Practice (USPAP). f I 5. 1am also a Property TaxProfessional, registered with theTexas Department ofLicensing 1 and Regulation. Assuch, I amregulated and adhere to statutes and rules that govern my practice |;

and that promote the highest standards of professionalism and ethics. k ft. Generally, taxable property is appraised al its market value as of January I. The S,; li property's value can never be more than ils fair cash market value. j| 7. Tlie market value of property shall be determined by the application of generally m

accepted appraisal methods and techniques. Further, each property must be appraised based jfj upon the individual characteristics that affect ihc property's market value and all available h\

evidence thai is specific- to the value of the property shall be taken into account in determining |j

the property's market value. Finally, in determining what the market value of a propcrtv is, three £! i approaches 1o value must be considered: (I) the cost; (21 income; and (3) sales comparison. The || most appropriate method must be used. fi.

8. The District determines the appraised value of properly using mass appraisal standards f that comply wiih USPAP. fr 9. The District adhered lo generally accepted methods for appraisal methods and techniques v;

to value the property that is the subject of this lawsuit. if. I 10. The chief appraiser, if required by law. provides property owners with notices of the f"' appraised and market values of inch: property. Given that it has personal liability for property ST

i Page 2 of4

I Sf^JS'if'

li taxes, a property ownermay protest, among other matters, a dclcrinination of the appraised value M

of the owner's property. Ig; U 11. The District provided the Plaintiff.Mr. Goad, with all notices of the appraised and market ,«

values of the propertymadethe basisof this lawsuit. |:

12. If a property owner in Guadalupe Countv is dissatisfied in any way with the value or an If; $ action taken by Ihc chief appraiser in a current tax year, Ihc property owner may protest. The j| property owner initiates theprotest by tilinga written notice with theappraisal review board. j|

13. After Ihc filing of a noticeof protest, the appraisal reviewboardholds a hearingand must j$ li timely notify theprotesting party. || S:

14. Once it has reached a decision on the protest, the appraisal review board must issue a p

written order embodying its decision. I j|

15. Within 60 days of its Having received notice ofa final, appealable order by the appraisal f s

review board on its protest, the protesting parly may seek judicial review of that order by filing suit in district court.

16. Every individual tax year, ihc Plaintiff, Mr. Goad, has had an opportunity to protest * in actions taken by tlie District or the chief appraiser, present evidence and argument, and be heard „

by the Guadalupe County Appraisal Review Board. As a result of this lawsuit, the District considered Mr. Goad to have filed a late protest of the property's 2014, appraised value. An appraisal review board hearing was scheduled and convened. Mr. Goad, had notice of Ihe hearing but did not attend and his protest was dismissed. Prior to 2014, Mr. Goad had not filed any protests of the appraised value of the property made the basis of this lawsuit with the I appraisal review board. Page 3 of4 f

17. The actions that were taken by the District regarding ihe property that is ar issue in this

lawsuit comport with the Constitution of the Slate of Texas, the "I'cxas Tax Code, tlie Rules of

the Comptroller's Office and with the standards of the Property Tax Assistance Division of the

Comptroller's Office, and the Uniform Standards of Professional Appraisal Practice (USPAP).

18. The District's actions regarding the property at issue in this lawsuit and my interactions

with the Plaintiff, Mr. Goad, have comported with the highest standards of professionalism and

ethics.

19. The District has treated the Plaintiff, Mr. Goad, and the property at issue in this lawsuit

fairlyand as any other property owner or propertyin Guadalupe County.Texas.

20. The District's actions regarding the property at issue in this lawsuit and interactions with

Ihe Plaintiff,Mr. Goad, have not been arbitrary or capricious."

Further Affiant Saveth Not.

.^anTieS^sbornc

Sworn ui and subscribed before me by Jamie Osborne on August /5" , 2014.

/SKSSSi YOIANDA SAENZ RWWf| Notary Public, Stateof Texas My Commission Expires December 14, 2015 Nfctiry Public. Slate ofTomST

Page 4 of4

r #£•;# ifis:•Tps-^^^^^'^s^^^v^^^i^^^^^^. zz^;5^;&i^'^t~sr:. •y&

-2~> g*s* Wv$ £*/?j6/ 't is APPRAISAL DISTRICT 3000 IV!. AUSTIN SEQUIN, TX 78165 0 ..-t/v<^

Hi

CompffoliM 50-132 (Rev. 2-98/3) ZS5S [41.44 (12/89) Rule 9.801] PROPERTY TAX - NOTICE OF PROTEST Appraisal district name Phone (Areacode and riurhher) GUADALUPE APPRAISAL DISTRICT 830 372 2871

Address

GUADALUPE APPRAISAL DISTRICT SEGUIN, TX 78155

INSTRUCTIONS: Ifyou want the appraisal reviewboard to hear and decide yourcase, you must file a written notice of protest withthe appraisal reviewboard (ARB) for the appraisal district that took the action you want to protest. Ifyou are leasing the propertysubject to the protest, you must have a contact requiring you to pay the property taxes on the property.

FILING DEADLINES: The usual deadline for filing your notice (having itpostmarked ifyou wail it)is midnight,May 31.

A different deadline will apply to you if: • your notice of appraised value was delivered to you after May 2; • your protest concerns a change in the use of agricultural, open-space or timber land; • the ARBmade a change to the appraisal records that adversely affects you and you received notice of the change; • the appraisal districtor the ARB was required by lawto send you notice about a propertyand did not; or • you had good cause for missing the May 31 protest filing deadline.

Contact the appraisal district for your specific protest filing deadline. The ARB will determine if good cause exists for missing a deadline. Good cause means that something beyond your control, such as a medical emergency, prevented you from meeting the_'lr~-":."_..._ WEEKENDS, HOLIDAYS: Ifyourdeadline falls on a Saturday,' Sundayor otherlegalholiday, Stepl Owner's Owner's or lessee's full name

SHEESLEYJOHN pjaxu^ /n&Zi ifcuJL or lessee's name and address Owner's or lessee's presentmailing address (number andstreet) 208 MORTON ho qua- o$$j^ju City, town or post office, state, ZIP code SAN ANTONIO, TX 78209 Step 2: Give streetaddressandcity ifdifferent from above, orlegal descriptic Describe ABS: 134 SUR: JOSE FLORES 1.000 AC. property under protest Appraisal district account number (optional) Property ID: 107520 GEO ID: 2G0134-000( A# Mobile homes: (Give make, model and identification number)

Step 3: Check D Value Is over market value c reasons LI Owner's name is incorrect for your l_l Change in useofland appraised as ag-use, open-space ortimber protest U Property should not betaxed in land

(name of taxing unit) U Ag-use, open-space orother special appraisal was denied, modified or cancelled U Failure tosend required notice. U Value is unequal compared with other properties. (type) LI Property description is incorrect. 0 Other. Li Property should not be taxed in this appraisal district orin one or more taxing units. Step 4: Give facts that may help resolve your case (continue on additional page if needed) What do you thinkyour property's value is? (Optional) $ Step 5: Iwant theARB tosendmea copy ofitshearing procedures. Check to receive ARB • Yes D No*

"jzishthii V* i hearing procedures *If your protest goestoa hearing, you will automatically receive Step 6: Signature Sign the sign application here ™ Tru« Automaton, Inc.

County of Guadalupe Guadalupe Appraisal District State of Texas Appraisal Review Board

MOTION TO CORRECT ONE-THIRD OVER-APPRAISAL ERROR

Movant SHEESLEY JOHN .owner of property described as ABS: 134 SUR: JOSE FLORES 1.000 AC. parcel number 2G0134-0000-01105-0-00. brings this motion for a hearing to correct a one-third over- appraisal error regarding the described property on the appraisal roll certified by this Appraisal Review Board on July 18, 2007.

Movant states that the property taxes due for the 2007 tax year have not become delinquent, and the movant property owner has complied with the provisions of Sec. 42.08 of the Texas Property Code and has notforfeited the right to appeal for non-payment of taxes.

Movant states that the property described above is located within the Guadalupe Appraisal District. Further, movant states that the property described above is located within the taxing units listed below:

CAD, GCO, LTR, MAS YHjbQ<^-

Movant states the one-third over-appraisal error is as follows: OUA- OtyS^CA, Appraisal value of $12.500is at least one-third over actual market value. Actual market value of property is $ .

Movant makes this motion pursuant to Sec. 25.25 (d) and (e), Texas Property Tax Code, and requests that the Appraisal Reviews Board schedule a hearing to determine whether to correct the error. Movant requests that the Appraisal Review Board send notice of the time, date and place fixed for the hearing, not later that 15 days before the scheduled hearing, to the presiding officer of the governing body of each taxing unit where the property is located.

Respectfully submitted,

. Date Movant

w* 50-132 (Rev. 2-98/3) "p*ic [41.44 (12/89) Rule 9.801] PROPERTY TAX - NOTICE OF PROTEST Appraisal district name Phone (Area code and number) 830 372 2871 GUADALUPE APPRAISAL DISTRICT Address

GUADALUPE APPRAISAL DISTRICT SEGUIN, TX 78155

INSTRUCTIONS: If you want theappraisal review board tohear and decide your case, you must file a written notice ofprotest with theappraisal review board (ARB) for theappraisal district that took theaction you want to protest. If you are leasing theproperty subject tothe protest, you must have a contact requiring youto pay the property taxes on the property.

FILING DEADLINES: Theusual deadline forfiling your notice (having itpostmarked ifyoumail it) is midnight, May 31. A different deadline willapply to you if: • yournoticeof appraised value was delivered to you after May2; • your protestconcerns a change inthe use of agricultural, open-space or timberland; • the ARB madea changeto the appraisal records thatadversely affects you and you received notice ofthe change; • the appraisal district or the ARB was required bylawto send younotice about a property and did not;or • you had good cause for missing the May 31 protest filing deadline.

Contact the appraisal district foryourspecific protestfiling deadline. The ARB will determine ifgoodcause existsfor missing a deadline. Goodcause means that something beyond your control, such as a medical emergency, prevented you from meeting the deadline.

WEEKENDS, HOUDAYS: Ifyour deadline falls on a Saturday. Sunday or other legal holiday,it is postponed untilmidnightof the next workingday. Stepl: Owner's or lessee's full name Contact

Owner's SHEESLEY JOHN or lessee's Owner's or lessee's present mailing address (number and street) Hm. Phone (area code and number) name and address 208 MORTON City, town or post office, state, ZIP code Bus. Phone (area code and number)

SAN ANTONIO, TX 78209 Step 2: Give street address and city if different from above, or legal description if no street address Describe ABS: 134 SUR: JOSE FLORES 1.000 AC. property under protest Appraisal district account number (optional) Property ID: 107520 GEO ID: 2G0134-0000-01105-0-00 Mobile homes: (Give make, model and identification number)

Step 3: Check LI Value is overmarket value U Exemption was denied, modified orcancelled. reasons U Owner's name is incorrect U Change in useofland appraised as ag-use, open-space or timber for your land protest U Property should not betaxed in (name of taxing unit) U Ag-use, open-space orother special appraisal was denied, modified or cancelled

LI Failure to send required notice. U Value isunequal compared with other properties. (type) U Property description isincorrect. D Other. U Property should not betaxed in this appraisal district orin one or more taxing units. Step 4: Give facts that may help resolve your case

(continue on additional page if needed) What do you think your property's value is? (Optional) $ Step 5: Iwantthe ARB to send me a copyof its hearing procedures. Check to receive ARB D Yes • No* hearing * Ifyour protest goes to a hearing, you will automatically receive a copy of the ARB's hearing procedures procedures Step 6: Signature Date Sign the sign application here ~ Title Automation, inc.

County of Guadalupe Guadalupe Appraisal District State of Texas Appraisal Review Board

MOTION TO CORRECT ONE-THIRD OVER-APPRAISAL ERROR

Movant SHEESLEYJOHN .owner of property described as ABS: 134 SUR: JOSE FLORES 1.000 AC, parcel number 2G0134-0000-01105-0-00, brings this motion for a hearing to correct a one-third over- appraisal error regarding the described property on the appraisal roll certified by this Appraisal Review Board on July 18, 2007.

Movant states that the property taxes due for the 2007 tax year have not become delinquent, and the movant property owner has complied with the provisions of Sec. 42.08 of the Texas Property Code and has not forfeited the right to appeal for non-payment of taxes.

Movant states that the property described above is located within the Guadalupe Appraisal District. Further, movant states that the property described above is located within the taxing units listed below:

CAD, GCO, LTR, MAS

Movant states the one-third over-appraisal error is as follows:

Appraisal value of $12.500 is at least one-third over actual market value. Actual market value of propertyis $ .

Movant makes this motion pursuant to Sec. 25.25 (d) and (e), Texas Property Tax Code, and requests that the Appraisal Reviews Board schedule a hearing to determine whether to correct the error. Movant requests that the Appraisal Review Board send notice of the time, date and place fixed for the hearing, not later that 15 days before the scheduled hearing, to the presiding officer of the governing body of each taxing unit where the property is located.

Respectfully submitted,

. Date Movant

Guadalupe Appraisal District Main Location Schertz Substation Jamie Osborne Paul Soto 3000 N. Austin Street 1101 ElbelRd. ChiefAppraiser Chairman Cecil Schulze Seguin, Texas 78155 Schertz, Texas 78154 Vice Chairman 830.303.3313 210.945.9708 ext. 202 Sylvia Schlather 830.372.2874 Fax 210.566.1334 Fax Secretary Greg Gilcrease Member Tavie Murphy Member

01/14/08 NOTICE OF HEARING 1/3 OVER-APPRAISAL SEC. 25.25 (d)

TAXING JURISDICTIONS:

CAD, GCO, LTR, MAS

RE: Account Number :2G0134-0000-01105-0-00 Legal Description :ABS: 134 SUR: JOSE FLORES 1.000 AC.

A hearing for 1/3 Over-Appraisal has been scheduled on the above referenced property.

Date :02/12/2008 Time :1:00PM-1:20PM Place : Guadalupe Appraisal District 3000 N. Austin St. Seguin, TX 78155

Per Section 25.25(e) of the Texas Property Tax Code, each taxing unit is entitled to present evidence and argument at the hearing and to receive written notice of the board's determination.

Respectfully Submitted,

Kathryn Vermillion, Secretary Appraisal Review Board

Guadalupe Appraisal District Paul Soto Main Location Schertz Substation Jamie Osborne Chairman 3000 N. Austin Street 1101 ElbelRd. ChiefAppraiser Cecil Schulze Seguin, Texas 78155 Schertz, Texas 78154 Vice Chairman 830.303.3313 210.945.9708 ext. 202 Sylvia Schlather 830.372.2874 Fax 210.566.1334 Fax Secretary Greg Gilcrease Member Tavie Murphy Member

01/14/08 Dear Property Owner,

The Appraisal Review Board packet includes your NOTICE OF PROTEST HEARING, which gives the time and date of your Appraisal Review Board hearing. It includes a copy of the "RIGHTS, REMEDIES, AND RESPONSIBILITIES" publication promulgated by the Comptroller of Public Accounts, and a copy of the GUADALUPE APPRAISAL REVIEW BOARD HEARING PROCEDURES adopted by the Appraisal Review Board.

You may inspect and or obtain a copy of the data/information, which will be introduced at the Appraisal Review Board hearing. You may also obtain a copy of the appraisal card for your property at no charge. The charge for copies of additional information will be the normal charge for that type of data, not to exceed $15.00 for each residence, or $25.00 for each other type of property.

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50-132 (Rev. 2-98/3) [41.44 (12/89) Rule 9.B01]

PROPERTY TAX - NOTICE OF PROTEST Appraisal district name Phone (Area code and number) 830 372 2871 GUADALUPE APPRAISAL DISTRICT Address

GUADALUPE APPRAISAL DISTRICT SEGUIN, TX 78155

INSTRUCTIONS: If you want theappraisal review board tohearanddecide your case,you must file a written notice ofprotest with theappraisal review board (ARB) for theappraisal district thattook the action you want to protest. Ifyou are leasing the property subject tothe protest, you must have a contact requiring you to pay the propertytaxes on the property.

FILING DEADLINES: The usual deadlineforfiling yournotice(having itpostmarked ifyoumail it)is midnight, May31

A different deadline willapply to you if: • your notice of appraised value was delivered to you after May 2; • yourprotestconcerns a change inthe use of agricultural, open-space or timberland; • the ARB made a change to the appraisal recordsthat adverselyaffects you and youreceived noticeof the change; • the appraisal districtor the ARBwas required by law to send you notice about a property and did not; or • you had good cause for missing the May 31 protest filing deadline.

Contact the appraisal district foryourspecific protestfiling deadline. TheARB will determine ifgoodcause existsfor missing a deadline. Goodcause means that something beyond your control, such as a medical emergency, prevented you from meeting the deadline.

WEEKENDS, HOLIDAYS: Ifyour deadline falls on a Saturday, Sunday or other legal holiday, it is postponed until midnight of the next working day. Stepl: Owner's or lessee's full name Contact

Owner's SHEESLEY JOHN or lessee's Owner's or lessee's present mailing address (number and street) Hm. Phone (area code and number) name and address 208 MORTON City, town or post office, state, ZIP code Bus. Phone (area code and number)

SAN ANTONIO, TX 78209 Step 2: Give street address and city if different from above, or legal description if no street address Describe ABS: 134 SUR: JOSEFLORES 1.000 AC. property under protest Appraisal district account number (optional) Property ID: 107520 GEO ID: 2G0134-0000-01105-0-00 Mobile homes: (Give make, model and identification number)

Step 3: Check U Value is overmarket value U Exemption was denied, modified orcancelled. reasons U Owner's name is incorrect. U Change in use of land appraised asag-use, open-space ortimber for your land protest U Property should not betaxed in (name of taxing unit) LJ Ag-use, open-space orother special appraisal was denied, modified or cancelled

U Failure tosendrequired notice. U Value is unequal compared with other properties. (type) U Property description isincorrect. D Other: U Property should not be taxed in this appraisal district orin one or more taxing units. Step 4: Give facts that may help resolve your case (continue on additional page if What do you think your property's value is? (Optional) $ needed) Step 5: I want the ARB to send me a copy of its hearing procedures. Check to receive ARB D Yes D No* hearing * Ifyour protest goes to a hearing, you will automaticallyreceive a copy of the ARB's hearing procedures procedures Step 6: Signature Date Sign the sign application here ^ Tru* Automation, Inc.

County of Guadalupe Guadalupe Appraisal District State of Texas Appraisal Review Board

MOTION TO CORRECT ONE-THIRD OVER-APPRAISAL ERROR

Movant SHEESLEY JOHN .owner of property described as ABS: 134 SUR: JOSE FLORES 1.000 AC, parcel number 2G0134-0000-01105-0-00. brings this motion for a hearing to correct a one-third over- appraisal error regarding the described property on the appraisal roll certified by this Appraisal Review Board on July 18, 2007.

Movant states that the property taxes due for the 2007 tax year have not become delinquent, and the movant property owner has complied with the provisions of Sec. 42.08 of the Texas Property Code and has not forfeited the right to appeal for non-payment of taxes.

Movant states that the property described above is located within the Guadalupe Appraisal District. Further, movant states that the property described above is located within the taxing units listed below:

CAD, GCO, LTR, MAS

Movant states the one-third over-appraisal error is as follows:

Appraisal value of $12.500is at least one-third over actual market value. Actual market value of property is $ .

Movant makes this motion pursuant to Sec. 25.25 (d) and (e), Texas Property Tax Code, and requests that the Appraisal Reviews Board schedule a hearing to determine whether to correct the error. Movant requests that the Appraisal Review Board send notice of the time, date and place fixed for the hearing, not later that 15 days before the scheduled hearing, to the presiding officer of the governing body of each taxing unit where the property is located.

Respectfully submitted,

Date Movant

Guadalupe Appraisal District Main Location Schertz Substation Jamie Osborne Paul Soto 3000 N. Austin Street 1101 Elbel Rd. ChiefAppraiser Chairman Cecil Schulze Seguin, Texas 78155 Schertz, Texas 78154 830.303.3313 210.945.9708 ext. 202 Vice Chairman 830.372.2874 Fax 210.566.1334 Fax Sylvia Schlather Secretary Greg Gilcrease Member Tavie Murphy Member

01/14/08 NOTICE OF HEARING 1/3 OVER-APPRAISAL SEC. 25.25 (d)

TAXING JURISDICTIONS:

CAD, GCO, LTR, MAS

RE: Account Number :2G0134-0000-01105-0-00 Legal Description :ABS: 134 SUR: JOSE FLORES 1.000 AC.

A hearing for 1/3 Over-Appraisal has been scheduled on the above referenced property.

Date :02/12/2008 Time :1:00PM- 1:20PM Place : Guadalupe Appraisal District 3000 N. Austin St. Seguin, TX 78155

Per Section 25.25(e) of the Texas Property Tax Code, each taxing unit is entitled to present evidence and argument at the hearing and to receive written notice of the board's determination.

Respectfully Submitted,

^±L/uY*nh^\JllL^ /}&JUL Kathryn Vermillion, Secretary Appraisal Review Board

\

DAVID GOAD *J* 1154 RIVERTREE DRIVE ^ ,/#. NEW BRAUNTELS, TEXAS 78130 Uff\6 X AfiYir 830-5,5-2052 \J ^t^U^ Aug.j»3,2009 y rAl^S-

Guadalupe County Tax Office P. O. Drawer 70 Seguin, Tx. 78155-0070 »*?>V.!.t Re: Goad, David C. Custodian for ;Kristin G. & Natalie H. Goad Account No. R146794 / 5~y ABS: 134 Sur. Jose Flores 1.000 Ac.

To Whom It May Concern:

Please be advised that Guadalupe County Sheriff's Officers stood guard while a fence was erected, permanently blocking access to the property. My inability to access the property renders the property useless/valueless. Federal litigation ispending with regard to these issues. Please direct the tax hill to Robert Etlinger, Assistant Guadalupe County Attorney, for payment.

Sincerely,

Jh^- {/ David Goad

I certify that on August 35 20091 deposited this letter in an official depository ofthe. United States Postal Service, properly posted byfirst class mail.

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Jamie Osborne

From: 1983remedies@gmail.com Sent: Tuesday, April 15, 2014 11:04 AM To: Jamie Osborne Subject Goad property photo Attachments: Document (3J.jpg

Hola, Attached please find the photo I spoke of.

Iwish to memorialize yoursUtements (April 15,2014) wherein your office hasnocorrespondence(s) from myself orthe Guadalupe County Attorney regarding the valuation(s) ofthe Goad property at Zuehl Airfield.

Thank You David Goad

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&H& ft Sanitized file

Subject: Sanitized file From: 1983remedies@gmail.com Date: 5/6/2014 11:49 AM To: Jamie Osborne <josborne@guadalupead.org>

Ifigured that someone in your office sanitized the file. Don't worry, I'm well documented. Thank You David Goad

On 5/5/2014 4:09 PM, Jamie Osborne wrote:

Mr. Goad,

Hello. I hope this finds you we'll. Attached are documents related to your request.

Thank you for your time and effort in this regard. Should there be any other items that ouroffice may further assist with, please advise.

Sincerely, Jamie Osborne, R. P.A. Chief Appraiser Guadalupe Appraisal District 3000 N. Austin Street Seguin, Texas 78155 830.303.3313 www.Quadalupeacl.ora Customer Service Survey-Please dick the link below and tell me how I am doing? Please place my name or email address in the survey. http://www.survevmonkey.eom/s/6DMXH9L CONFIDENTIALITY STATEMENT Thistransmission is intended only for the persons or entities to which it is addressed. The information transmitted herein may-be(l) proprietary or strictly confidential material, (2) be subject to the Attorney-Client Privilege, or (3) an attorney work product. Review, reproduction, retransmission, distribution, disclosure or any other use, and any consequent action taken by persons or entities other than theintended recipients, are prohibited and may be unlawful. If you have received this in error, please contact the sender only and delete and destroy all forms of this communication (electronic and paper). Unauthorized interception of the email is a violation of federal criminal law. Although reasonable precautions have been taken to ensure that no viruses are present, the Guadalupe Appraisal District, makes no warranty or guaranty with respect thereto, and is not responsible for any loss or damage arising from the receipt or use of this e-mail or attachments hereto. Please be advised that the Guadalupe Appraisal District does have an Email policy that includes monitoring and may include printing out and reading all email leaving, entering, or stored in these systems.

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PROPERTY TAX - NOTICE OF PROTEST - 2013 Appraisal district name Phone (Area code and number) GUADALUPE APPRAISAL DISTRICT 830372 2871 830 303 3313 Address ™~" ~~ ~~ 3000 N AUSTIN STREET SEGUIN. TX 78155 "TWTdOTlittiKmSreT^ of the Texas Comptroller of ftiUc Aecourta,

GENERAL INSTWCTlO^Pumi^ toTa*Code Sorton41 ^ or dwfgrated atftit*tto wowW tikethe ARBto haw anddeo'itaa protesl.iryou are i«»Mi9[h»property, you *-«suaj«a to ttwilmnawim set fort»i«< Tm Co* Section 4V413. .

RLWQDEADLINES: TheucualitoMllriefdrfiUn0yoitf{tM«ais(riB>tig», ffciy31 AdfteremdaadlirtattMJBppiylojfOoif. . • your notice ofappraised «« «uottfrered after May 2; • your protest concerns e ohartpBin Bw use of agricultural,opftrt-flfleeaof Ifflbw land. • fte ARBireoa • changetoine appraisal more* thata^mui^^Kiiy^wdvouncatiaandiXBoimeatmse, • theappraisal dutrtt orif* ATOwear^^ • incertain limnedcircumstances, you had goat cau» forrrfesinQlhe May 31 protesl n^ngdeadline Yourjp«or«pn^iia^de8dlifffibpnr)l«danmeapOfarsal^.ic«

ASSISTANCE; TrwCrjapvclerscrftamayrifjiac^ llttjConpcroUftfi officeknowsis the subjectof a ottost 10trtaARB. Stata die Yearfa) forWhichYog are Protesting: ;

Stspl: Owners or lessee's first *»*• 4 irrttai Owneffi GOAD DAVID arreews name and Qw^»«iftM*seu*OTffl*fir»5»5*TO address CUSTODtAN FOR NATALIE H GOAD 1154 RtVERTREE OR NEW BRAUNFEL5.TX 78130 OajrttosPrnra^BivacoAeaiffwailier) EvgrengPhone fans*code ««f numoer}.

Step 2: GtaUfMadrfreu art dM divert Irm Describe WaPSOCKTX-A88 134SU* JOSEfLOftES..00OAC. under protest

Pmpariy in-irrrsTn «nn in- ?nni^j^fintuinn.s.njifi : tt9MshonttKr&winateJaodfer0fi*aeffKc4taffj>iMitie0

^™™,*™™™S™'"™W»»*»«<«W^»l«i«^Vsl«»u«^ Ma»»mi[Dc«w(rte»««r.you»sjv*a!:in0l>a1)^uro:c(Mny.-s™«porsi5Ma: ™<™i«^»i«pi»»»n*e«»^oroM«Mto Vowproperlr*«rt««pt™i«il«ilj™*ilvii«j<i. »tppralsal (ad««7boi«l mayoonddwyour pstntatsDnJkv tBUw. tslnatUie«ppr8lstt(»J««boi<4qiaraoiK)dw«Durai>Mtatn)riJkiatBliM.

Value Is over market vakre- Exemption was denied, modified or canceled. 3 VWueis unequal compared w» outerproperties Changein use of tartdappraisedas ag-use, open-space, or timber tanrj.

Property shoos)not tietaxed In • Ag-use.open-space at other special appraise) was denied, (name oftvtttiQfmXl D modified or cancelled. Failure to sera required noses. Stupe) Li Owners name is incorrect

OUisr: Property description is incorrect. a Propertyshould not be taxes in this appraisaldistrictor <n one or • mens taxing onils.

Step 4: Give facts that may help resolve yourcase (continue on additional pegeff needed) Whaloo you Vwkyor property*vtfLe i& (Opilowtl) StepS: i Mm theARB to a ma a copy of its hearing proceduroa. Check to receive ARB ]Yes hearing procedures QY~ D ** 'Bywpfplaaigowc»aNB^,»<ai^«t<Qni«ialiyrariiliuacapyrf^AflBf>i)eaf^8gpCTdurgx Stapfi: print . Stgntha here * protest sign ,

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PropID: 107520

Property Tax PropertyAppraisal - fetice ofProtest Form 50-132

830-303-3313 Guadalupe ApprafeaUDisfrict^ Phone(area code andnumber) Appraisal District's Name 3000 N. Austin Street Seguin, Texas 78155 Address „ ^..^fiio 3 written notice oforotestwith the appraisal review board <ARB) for

rlmg ouDUHaBt-n. m^i dUa»e-«^-w^-b^;!?--™«po*r-*^ *1!~ •• "*«»l* m« at pi A different deadline wOl apply toyou it = . vournotice of appraised value was delivered toyou after May 2; =

Contact the appraisal review board tor your specific protest fftng deadline. „.,"...,

deadline or grant a rescheduling." . ^^^^ ASSISTANCE: The Computer (including the Property Tax AteWano. DhetaO mw n« ^ anappraSrevilboardon anUwtratthecorcqttrcJarta^ STEP 1: Owner's.or lessee';

Last Name Owners or Lessee'sfirst ir Lessee's Nameand first Name and Initial Initial a

i Current Mafling Address dumberantfsfisetj

Phone (area code and number) City, State,ZIP Code

Give Street Addressi andCity ifDfflererft from Above, oral /**y**A ^0 /o?$?-0 ApprausalDfetrWAceountNiOTberflf^WlllrTJ) ,-' - 5»&£ :»c >~- , * .v. 5

Mobile Homes (give make, modal andidentification number} STEP 3: Check reasons for your r^retocrMH*ab«mayre*jBtoyw „ . . „,. and vour property would not seD for the amount rjetemiir^ bytr»appraisal district that your property isnotappraised at the same leveJasa^reserrtativesarrir^ofcorr*^ otheMadr^wr prorjerty may be awrais^ at its coR*Bia*p!ope^ ^Value ta ovor market value. j SChange inuse ofland appraised asap-use. open-space ortimber land. rValue is unequal compared with osier properties. f ~] Ag-use, open-space orcither special appraisal wasdenied, modified orcancelled.

i—i ' jOwner's name isincorrect ] Property should notbetaxed in 7^fPtc^e^4esc^iSonis,intx^iear_ ,. ,, ,„ Failure to send required notice. Fj Property should not be taxed in this aorxarsaldistrWorin^oriTOretaxirrgurifls. fiype) ] Exemption was denied, modified orcancelled. IK Other. ™** /tS »i;Trtt<£r'1~4*x*!L-- ## I J- The Property Tax Assistance Division atthe Texas Comptroller of Publip Accounts provides property tax irrformation and resources for taxpayers, local taxing entities, appraisardistricts;and..appraisal review boards; 3-n/u

Vikfr&^B STEP 4: Give facts that ma>

////>sr ,j ^ f^n^^/y^f^ *i0j7&&*fi / What do you think your property's value is? (Optional) $.

Iwant the ARB to send me acopy ofHs hearing procedures. CD Yes j~l No*- *If your protest goes to a hearing, youwill automatically receivea copy of theARBi hearing procedures.

STEP 6: Sign here. *"> Age 2 • 50-132•03-12/11

Do Not Pay From This Is NOT a tax This Notice Sfafemertt

GUADALUPE APPRAISALDISTRICT Property ID 107520 3000 N. AUSTINSt. Ownership %: 100.00 Geo ID: 2G0134-0000-01105-0-00 SEGUIN. TEXAS 78155 Phone: 830/372-2871 630/303-3313 DBA- Pax: 830/372-2874 Legal:ABS: 134 SUR: JOSE FLORES 1.000 Schertz Office: 210/945-9708 Ext 202 AC. Legal Acres: 1 April 8,2013 Situs: WWDSOCKTX Owner ID: 157096

Property ID: 107520 - 2^34-0QOHtt105-fj-00 GOAD DAVID CUSTODIAN FOR NATALIE H GOAD 1154RrVERTREEDR NEW BRAUNFELS, TX 78130-2425 i'»-iii-iii,i-iii,it,*ini»,-,ih,ii,'imiitiw«-",|i*tii»» APPRAISAL NOTICE

Dear Property Owner, We have appraised the propertyfistedabove for (he taxyear2013. As of January 1, our a 5praisalis<waned below:

SSKStsiasBSBm^SSS^SKSSm^ms-ji Structure / Improvernent Market Value 0 o• I Market Value of Non Ao/fimoer Land 12.560 21.713 ! Market Value ofAq/Timber Land 0 0 Market Value of Personal Property^Minerals 0 o ! Total Market Value 12.500 21.713 ! Productivity Value of Ao/llrnber Land o 0 | Appraised Value* (PossJrte Homes^eadijnRt^iKOQE^ seeastern oeknv) 12.S00 71 7t? ! Homestead Cap ValueexchK&w NervHorne^fe %*» <Le. Ag. Commercial} B n i Exemptions *

12,600 GUADALUPE COUNTY 21,713 21,713 0.346600 75.04 12,500 UflBWL ROAD 21.713 21.713 0.056000 - 12.69 12,500 MR!ON ISO 21,713 21,713 1.280000 277.02,

Do NOT Pay From TWe Notice The difference between the2008 apprised vnfciearid tr»propos^2013^)()r»sodvah»is73.70%. This percentage fttformation is requiredbyTw Code section 2S.19(b-1).

The TexasLoa^staisac^^matait^HimiUifmiifuir^mi'kTiir^aiS, Tikfrpnypariy'tm rmrrthirTrTir ifryMKnr/jwrTrfncnfljririfcirfmtofrikiiitn niwf nff b0i&mcfStt>thex*olJiciMls.

Theabovetax estimates use lastyeart taxratesforttetarir^urtestawn, Tte governing bodyof each unit(school board, cowtycoiMitissioners, cityawnca aid so forth) decxJeswrtetherrxor^taxesmereasa Theappra^ 'Your reader** homestead* protectedlh^ improvements. * : ~ Ifyouare 65 yearsof age orolderand receivedfee$10,QD0acnooi tax exemptionon yourhome bat wflinotbe rngtrer than Mtenyw firstrecer^tto ab0ve,yoursdwoItaxesfbrB%yearw>notbel^^ ffvoureoonfr " rvoureceivedtrieexemption, wheneveris later. Byoureois^ety.orJtrrtoeoBeoehas approvedafimitafiononyourlaxesifttep^ . _ atMps nfl nrt hithitfterthanthe ftst-ynaryaycoiinHy, rpf, r»^nwi^^wMp^ef) tfrp tirretatton or tr* firstyear you viafir^ appraisal roB, yourschool; county, oHy, orJunior caBef^cefc^fBa*Increase farm county,crty,orJunkvcotege tax oeSnp- prc*£r?c»&rSs1&^ *•» To appeal, you must filea written protestwffljthe ARB before «bedead*ne date: Deadline for fffina a protest M«y31.2013 luxation of Heartngs: 30rJO*. AUSTIN ST/S£GU1N.TX 78155 ARBwrfflbegmhearings: tlay8?20ta Endosedisarxotestformtosendt^appraisaiolstrtdoaeeif' evidence before the ARB. The ARB wffinotifyyou of the date, time and place of your scheduled hearing. Enclosed, also, isWbrmation to hesyoui. yourpretest You do not need to use Ihe enclosed formto fileyourprotest You inay protestby letter, if it mdudes your name, yourrjroperty*desato6m,and:yewm ^ Ifyouhaveanyo^iestioris orreed nioreIntonnaSon, p^ Sincerely, Chief Appraiser

Susan Combs Texas Comptroller of PublicArxoi

You are entitled to anexplanation of mast have awebsite. Contact your lo your concerns atthe informal meeting the remedies available to youwhen cal appraisal district formore details on with the appraisal district. youare not satisfied withtheappraised fifapg aprotest electronically. value assigned to your property by your Find out theprocess your appraisal dis appraisal district. The Texas What Can be Protested trict follows. Try todiscuss your protest Comptroller of Public Accounts is The Notice ofPrstest may be£led using issue with the appraisal office in ad required to publish an explanation of vance. Askone:of theappraisal district's thcremediesavailable tOTaxpayewanri ' ^t^r^t^m^v^iimstaivt^iaejxatsf - appraisers to fxpfcrtrt how the district . procedures tobe followed inseeking taxmfWl»xfoniis/50-132.|»df. The no arrived atthe value of your property. Be remedial action. The Comptroller also ticeneed not be oo this form. T&ur no sure the property description iscorrect must include advice on preparing and ticeofprotest is sufficientifit identifies and that the measurements for your presenting a protest. (1) me protesting person claiming an home or business andlot are accurate. ovCTership interest inthe property, (2) Many appraisal districts have this infor The Legislature further directs that cop d» property that is thesubject of the mation online. ies ofthis document be made readily protest and 0) dissatisfaction with a available totaxpayers at- nocost. Tee • Ll»f .* ._J t\^ What is an ARB? chiefappraiser ofan appraisaldistrict - 'Bre^AjQBis-aii iadejpeadent, impartial may provide acopy with theNotice •• ofAppraised Value mailed to property _ oa-your . gfAU^<^Qtiz£^autWri^tore^€ .property in situations: disputes betwieejfi &xpaj$B aiddje^ owners toexplain the time and proce appraisal district.AfetiotigH, infmost dures used inprotesting the value of * thevafete theappraisal district cotumes, theARBisappMnied bythe their property. The chiefappraiser must placed on your property is too high; appraisal district board ofdirectors, it is provide another copy to property own * your property is unequally notcontrolled by theappraisal district. ersinitiating protests. appraised; The first step in exercising your rights * fbeappiaisal district denied aspe- Bringing aprotest before theARB isa under the Tax Code is to protest your dal appraisal, such; as open-space formal process; itissomewhat like talcing property's appraised value. The follow , .land, ormeprreedy denied your a caseto a court for resolution. TJheARB ing remedies only address appraised „ ^aempticarsappkeation; rnust^lkrwcenaui procedures dut may values and related jnattersTT^venmient— *''the jfppiilfig Jjirifiu Jajfcd to pjfr.— bgiiw&n^r^yai^IxraHstbase its spendingand taxation arenot the sub vide yoywithrequired notices; or jects ofthis publication and must be the appraisal district to decide whether * other nuneR^rescribedbryTex. the appraisal district has acted property in addressed bylocal taxing units. TaxCoae§4Ui(a). determining the value ofyour property. How to Protest PropertyValue ARBmembers cannot discuss your case Ifthe appraisal district appraises your Prot^rtmn with anyone outside ofthe hearing. property at ahigher amountthan in the You should know, however, that your previous year, state law requires the ap Iflujjjgthe p^^rjpjrm, these tips protesthearing isopen todie public; praisal district send anotice by May I, *wp&p tssaK dwt.yott can present yoffrevidence and^re^rye your appeal anyone can sit in and listen to me case. or byApril 1if your property isaresi rights. dential homestead, 01 as soon as practi cal thereafter. The notice musrseparate ,-*• 5bru stjctujtf pay- particular attention Tfou shoaJd fifc you*Notice efPnta* the appraised value ofreal and personal 'tothe reason for protest section of widi the AiRB as Jatet than 30 day$ af- property and showan estimate ofhow the form. terthe appraisal district mailed theNo much taxyou would have to pay based tice ofAppraised Vahte. You may request on the same tax rate your dry, county, 9 ^hatyou^eck as the reason for meprotestinfluences the type of an evening orweekend hearing. The school district and any special purpose ARB wfll notify you atleast 15 days in district set the previous year. - evidence youinay present atyour - hearing. . , ,- advance ofthe date, time and place of The notice will also indude the date and •* Ifeur your hearing. Ifyouare not represented efaear- place th? appraisal review board.CARB) fog are by anagent, youare entided to one :you will begin hearing protests and may tell P/?S3!88ffl»3£:9Ctp*oearingj^ajager

SfSJPE Of TEXAS )./•:. ) < KBOW Alt MSJ BY THESE PRESENTS

Office of Tavle Murphy Tax Assessor-Collector

Installment Agreement

s«&*r2ri&rrs^ss^g^1s&'=it * —» Pursuant S^ect!^1!?^/8? C°U^f f°r the tax ™U *«tie««d hereby acknowledges that ^ss^^ss^^^ss^ tsjzr,st*tato*y auth^ -vv £ not to exceed 36 months" ajuln<I»«« t«es, penalty and interest over a period of tin*

and penalty which win accrae on^ JLf?SV * of this date in addition to interest CoderPayer VftarS^JJrlS^ £v wtTS^ *? " P"1**^ the Texas Property Tax taxing unit which a«StriSbiHty^f £ Fav«r I* 1?*^?******** lwi^ '* ***

II.

SiiSEfS **%EZJS^27^Z * thi9 »"1"—'< •'.^«»"-m'.*a filed for WrtA^r&^aTS s^edtrt^* »«. aerein he seized T **?'* or sold unless °*'«**•*?««**, the Payer defaults under nor this will the Agreeawxt. *' "SJwaSs"*" *payn,ent: as weired by this 2, railing to pay, when due> any other property taxes the liability of the Payer; oiT 3. Breaching any other condition of this Agreement.

2S?nSSiri?S Sr^LT.T^'^^ collector^ proceed to date of the execution of^hie^tall^SrSLnt ^^ *"**' "^ ** *"**** °B the III.

£ ^^Kft^^ «» *" <*"•«« —1* *«- the right doe and owing under this SLaSafSSf^^^T* ***' Penalt* «* interest still It i, agreed that the tL cSSSL'SS intervene filed by other taxing units. SSLSTfn"* •"""•»'» '••* « permitted by law. in any suits against Payer which may be

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1 I Installment Agreement Start Date:, 10/30/2013 I Owner: GQftD DAVID e~\ >k j faxing Onit!s): Marion Isd, Lateral Roads, Guadalupe County 'AJ W-^ « | Year(s) for which taxes are delinquent: 2012, 2011, 2010, 2009, 2008 I J /C*)* IC_J i f Delinquent taxes not including penalty, interest or attorney fees as of this date: 5902.28

Property Description 2G0134-0000-011Q5-0-*00 -R14j6794-. ABS: 134 SUR: JOSE FLORES 1.000 AG.

Method of Payment: Taxes, penalty and interest shall be due in installments of §50.00 ox more each, payable Monthly, 30th day of every month beginning 10/30/2013 and continuing regularly thereafter until all delinquent taxes, penalty and interest have been fully paid. Place of Payment! Office of Tavie Murphy Tax Assessor-Collector Guadalupe Tax Office 307 ». Court Seguin, TX 78155

Witness Lrness the tne signatures of or the the oarties oar this 09/05/2013

By: ^MC>^-^(^J>t^*£^' GOAD DAVID /«"*«<*3fl'360W CUSTODIAN FOR HftTALIE H GOAD

HEW aRADHFELS, TX 78130

By:)QZ£^4^a. Office of Tavie Hurphy••"lax Assessor-Collector

PAGE2QF2 ma*limQt$mitat1:22:S*P!6

CAUSE NO. JSC4-4995

DAVID GOAD § IN THE JUSTICE COURT Plaintiff, § v. § § PRECINCT NO. FOUR JAMIE OSBORNE § Defendant. § § GUADALUPE COUNTY, TEXAS AGREED RECORD OF SEPTEMBER 10.2014 HEARING

This AGREED RECORD of the September 10, 2014, hearing comes unopposed by the defendant or Judge Friesenhahn. Therefore, in the name of justice, it is agreed, this record shall memorialize the hearing that day. 1. Judge: We are here on two cases David Goad v. Erick Strey, and David Goad v. Jaime Osborne. 2. Judge: We are going to address the motions in the order received by the court. 3. Goad: Objection, The Motion for Fair Trial and Venue Change should be addressed first, it sets precedence over all other motions because it is written law, and I can find no exception to that law, a new law, first adopted one year ago, it is also a constitutional issue. 4. Judge: The problem is it is a Fair Trial Venue motion and were not at trial. 5. Judge: The motion is denied. 6. Sloan: There are three grounds in the partial summary judgment in which my clients are

entitled to, governmental immunity, substantive due process, and procedural due process. Mr. 9* frfi/i,* "2/

Goad did not participate in either, as he did not make a protest in the relevant years. This is a lawsuit that should be filed against the appraisal district and not my clients. Mr. Goad's pleadings are groundless and should not be allowed by this court. 7. Goad: I object to everything that wasn't plead in his first responsive pleading. We are here on an issue of immunity. This whole hearing should be focused upon that. I will speak on federal law because it is over state law. The state cannot make a law the trumps federal law as I have stated in my pleadings. If I could have brought in witnesses today this thing would be over with and all we would have to do is assemble a jury for damages. Hopefully, and indictment would be issued. 8. Goad: (Reads from his First Amended Complaint): #6 thru #24. I provide both law from

the United States Supreme Court and the 5th District which is over this court. This is all based upon federal law.

9. Judge: We're going by state law because we're in state court not a federal court. 10. Goad: Can I pull up federal case law to prove my point. I have all the books here on the federal case law that allows state courts to hear these matters. Also, state law does not allow immunity when someone acts in a fraudulent manner. 11. Judge: We are here for two motions, immunity and subject matter jurisdiction. I agree that state law does not trump federal law, but we are not in federal court we are in state court. 12. Goad: I would like to cite federal law from the books I brought from the number one man quoted in the U.S. Supreme Court. You cannot erase federal law because we are in a state court. 13. Judge: The problem is I don't have jurisdiction in this case. This case has to be in district court. You say you sued them individually and not the appraisal district, its got to be in district court. I cannot hear a case against the appraisal district, sorry. When the documents were stored at the appraisal district and sanitized the appraisal district was involved. I have no jurisdiction in this case.

Respectfully submitted.

DAVID GOAD, Plaintiff 1154 Rivertree Drive New Braunfels, Texas 78130 830-515-2052

CERTIFICATE OF SERVICE The undersigned certifies that on Sept 24, 2014, this AGREED RECORD was served on all parties in accordance with Texas Rules of Civil Procedure as set out herein below:

Jeremy R. Sloan, Esq. 16500 San Pedro., Suite 410 San Antonio, Texas 78232 U.S. Mail

David Goad

Footnotes

[1] ]i i •

[11] kfaP;./£•**' 4 £*tit»t Cz 1 ofl 8/25/2014 11:01 AV AND PROCEDURE 25th, 2nd 25th, and 274th Judicial Districts of Texas Guadalupe County The Honorable Dwight Peschel The Honorable W.C. Kirkendall The Honorable Gary Steel Judges Presiding 2005 \'rt* £*M*f)