Citation/Notice Text :

TO: Unknown Heirs at Law of MICHAEL J. HOLDEN, Decedent and to all whom it may concern: NOTICE TO DEFENDANT: “You have been sued. You may employ an attorney. If you or your Attorney do not file a written answer with the Clerk who issued this Citation by 10:00 a.m. on the Monday next following the expiration of 42 days after the date this Citation was issued, a Default Judgment may be taken against you.” You are hereby commanded to appear by filing a written answer to the Plaintiff’s Original Petition and Request for Temporary and Permanent Injunction at or before 10:00 o’clock a.m. on the Monday next after the expiration of 42 days after the date of issuance of this Citation the same being Monday the 15th day of February, 2021, before the Honorable 412th District Court, Brazoria County Courthouse, Angleton, Texas. Said Plaintiff’s Petition was filed in said court on the 16th day of September, 2020 in the above entitled cause. A brief statement of the nature of this suit is as follows: Plaintiff Jacquelyn D. McAnelly, as Substitute Trustee on behalf of Texas Dow Employees Credit Union, brought suit against Defendants Deborah Shanks a/k/a Deborah Holden, the surviving spouse of Decedent; Tammy Powers, the surviving daughter of Decedent; Michael John Holden, Jr., the surviving son of Decedent; and the Unknown Heirs at Law of Michel J. Holden, Decedent, to enforce the Loan Agreement on the property located at 106 County Road 416, Brazoria, Texas 77422 and legally described as: A 3.32 acre tract of land out of a called 7.348 acre tract out of the L.R. Smith called 201-2/3 acre tract out of the Rebecca Cummings League, Abstract 58, Brazoria County, Texas; said 3.32 acre tract being more particularly described as follows: A 3.32 acre tract of land out of a called 7.348 acre tract out of the L.R. Smith called 201-2/3 acre tract out of the Rebecca Cummings League, Abstract 58, Brazoria County, Texas, said called 7.348 acre tract being described in Volume 1434, Page 518, of the Deed Records of Brazoria County, Texas; said 3.32 acre tract being more particularly described by metes and bounds as follows: BEGINNING at a 1/2” iron rod found for corner at the intersection of the Southeast right-of-way line of County Road 416 (Brazoria County) with the Northeast right-of-way line of County Road 461 (Brazoria County); THENCE; North 45 deg. 28’ 09” East 629.34 feet, along the Southeast right-of way line of County Road 416, to a 1/2” iron rod found for corner; THENCE; South 44 deg. 40’ 18” East 226.89 feet, along the Northeast line of said called 7.348 acre tract, to a corner fence post found for corner; THENCE; South 44 deg. 49’ 15” West 626.44 feet, along the Southeast line of said called 7.348 acre tract, to a concrete monument found for corner; THENCE; North 45 deg. 23’ 15” West 234.00 feet, along the Northeast right-of-way line of County Road 461, to the Place of Beginning; Said tract therein containing 3.32 Acres of Land. Relief Request Required: 1) A declaration that Plaintiff has a lien against the Property in an amount equal to the pay-off of the Loan Agreement. The property address is 106 County Road 416, Brazoria, Texas 77422, with a legal description as set forth above. 2) An order authorizing Plaintiff to foreclose its lien created under the Deed of Trust in compliance with the Loan Agreement and Texas Property Code § 51.002. If filing Pro Se, said answer may be filed by mailing same to: Brazoria County District Clerk’s Office, 111 E. Locust, Suite 500, Angleton, Texas, 77515-4678 or by bringing said answer in person to the aforementioned address. The name and address of the Attorney for Plaintiff is Jacquelyn D. McAnelly, Cersonsky McAnelly & Garcia, P.C., 1770 St James Place, Suite 150, Houston, TX 77056, 713-600-8500. The Court has authority in this suit to enter Judgment. Any such Judgment will be binding upon you. Issued and given under my hand and seal of said Court at Angleton, Texas, on the 29th day of December, 2020. Deputy: /s/ Sunnye Wingo