United States of America v. 65.791 Acres of Land, More or Less et al

Filing 1

COMPLAINT against All Defendants filed by UNITED STATES OF AMERICA. (Attachments: # 1 Civil Cover Sheet)(Smith, John)

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Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 1 of 28 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS MCALLEN DIVISION UNITED STATES OF AMERICA, § § Plaintiff, § § v. § CASE NO. 7:18-CV-329 § 65.791 ACRES OF LAND, MORE OR § LESS, SITUATE IN HIDALGO COUNTY, § STATE OF TEXAS; AND THE ROMAN § CATHOLIC DIOCESE OF § BROWNSVILLE, TEXAS, ACTING BY § AND THROUGH ITS BISHOP, THE § MOST REVEREND DANIEL E. FLORES, § AS BISHOP OF THE ROMAN CATHOLIC § DIOCESE OF BROWNSVILLE, AND FOR § HIS SUCCESSORS IN OFFICE, ET AL., § § Defendants. § ______________________________________________________________________________ COMPLAINT IN CONDEMNATION ______________________________________________________________________________ 1. This is a civil action brought by the United States of America at the request of the Secretary of the Department of Homeland Security, through the Acquisition Program Manager, Wall Program Management Office, U.S. Border Patrol Management Office Directorate, U.S. Border Patrol, U.S. Customs and Border Protection, Department of Homeland Security, for the taking of property under the power of eminent domain through a Declaration of Taking, and for the determination and award of just compensation to the owners and parties in interest. 2. The Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.§ 3. The interest in property taken herein is under and in accordance with the authority 1358. set forth in Schedule “A.” 4. The public purpose for which said interest in property is taken is set forth in Page 1 of 3 ROE Complaint Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 2 of 28 Schedule “B.” 5. The legal description and map or plat of land in which certain interests are being acquired by the filing of this Complaint, pursuant to the Declaration of Taking, are set forth in Schedules “C” and “D.” 6. The interest being acquired in the property described in Schedules “C” and “D” is set forth in Schedule “E.” 7. The amount of just compensation estimated for the property interest being acquired is set forth in Schedule “F.” 8. The names and addresses of known parties having or claiming an interest in said acquired property are set forth in Schedule “G.” 9. Local and state taxing authorities may have or claim an interest in the property by reason of taxes and assessments due and eligible. WHEREFORE, Plaintiff requests judgment that the interest described in Schedule “E” of the property described in Schedules “C” and “D” be condemned, and that just compensation for the taking of said interest be ascertained and awarded, and for such other relief as may be lawful and proper. Respectfully submitted, RYAN K. PATRICK United States Attorney Southern District of Texas By: s/John A. Smith, III___________ JOHN A. SMITH, III Assistant United States Attorney Southern District of Texas No. 8638 Texas Bar No. 18627450 One Shoreline Plaza North Shoreline Blvd., Suite 500 Corpus Christi, Texas 78401 Telephone: (361) 888-3111 Page 2 of 3 ROE Complaint Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 3 of 28 Facsimile: (361) 888-3234 E-mail: jsmith112@usdoj.gov Attorney in Charge for Plaintiff And MEGAN EYES Assistant United States Attorney Southern District of Texas No. 3135118 Florida Bar No. 0105888 1701 W. Bus. Hwy. 83, Suite 600 McAllen, TX 78526 Telephone: (956) 548-2554 Facsimile: (956) 548-2776 E-mail: Megan.Eyes@usdoj.gov Attorney for Plaintiff Page 3 of 3 ROE Complaint Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 4 of 28 SCHEDULE A Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 5 of 28 SCHEDULE A AUTHORITY FOR THE TAKING The property is taken under and in accordance with 40 U.S.C. $$ 3113 and 3114, which authorize the condemnation of land and the filing of a Declaration of Taking; the Act of Congress approved September 30, 1996, as Public Law 104-208, Division C, Section 102, 110 Stat. 3009-546,3009-554, as amended and codified at 8 U.S.C. g 1103(b) & note; and the Act ofCongress approved March 23, 2018, as Public Law 115-141, div. F, tit. II, 132 Stat. 348, which appropriated the funds which shall be used for the taking. Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 6 of 28 SCHEDULE B Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 7 of 28 SCHEDULE B PUBLIC PURPOSE The public purpose for which said property is taken is to conduct surveying, testing, and other investigatory work needed to plan the proposed construction of roads, fencing, vehicle barriers, security lighting, cameras, sensors, and related structues designed to help secure the United States,Mexico border within the State of Texas. Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 8 of 28 SCHEDULE C Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 9 of 28 SCHEDULE C LEGAL DESCRIPTION Hidalgo County, Texas Tract: RGV-MCS-2212 Owner: ROMAN CATHOLIC DIOCESE OF BROWNSVILLE, TEXAS, ACTING By AND THROUGH ITS BISHOP, THE MOST REVEREND DANIEL E. FLORES, AS BISHOP OF THE ROMAN CATHOLIC DIOCESE OF BROWNSVILLE, AND FOR HIS SUCESSORS IN OFFICE. et al. Acreage: 4.781 As identified in the Warranty Deed, Document #: 1999-814019, recorded on October 12, 1999, in the Deed Records of Hidalgo County: EGINNING at a 3-inch steel pipe with nail found in the northwest boundary line of the 300-acre reserve and being the west comer ofa 35.81-acre tract as recorded in Volume l2l4,Page 1014, Deed Records, said 3-inch steel pipe alsobeing inthe southwest line of the Intemational Bomdary and Water C,ommission (IBWC) River Levee as recorded in Volume 488, Page 636, Deed Records; B Thence, departing said northwest boundary line with the southwestboundary line ofthe said 35.81-acre tract and IBWC River Levee, same being the northeast boundary line hereof, S. 01' 57' 36" W., 109.56feet to a 3-inch seel pipe with nail found for an angle point; Thence, containing along said bor.urdary lines, S. 15'03' 15" 8., l38.90feet to a 3-inchsteel pipe with nail found for an anglepoint; Thence, continuing along said boundary lines, 5.74" 56' 45" W.,40.D feet to a %-inch$eel rod st for an angle point; Thence, continuing along said boundary lines, S. 15" 11'20'E.. 183.69feet Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 10 of 28 to a %-inchseel rod set atthe northemmost comer ofthe U.SA. Tiact 332a. as recorded in Volume 2825, Page I 16, Deed Records; Thence, departing said suthwest boundary line with the northwest boundary line of said Tiact 3324 S. 60" 28' 10" W., 111.88 feet to aunited States Fish and Wildlife Service (USFWS) aluminum monument found for a comer; Thence, continuing along the said northwest boundary line, N. 29.3 to a 1' 50" W., I 1000 feet USFWS aluminum monument found for a oorner; Thene, ontinuing along the said northwest boundary line, S.60"28' 10" W.. 85.00 feet to a USFWS aluminum monument found for a corner; Thence, continuing along the said northwe$ boundary line, S.29' 31' 50" E., 40.00 feet to a USFWS aluminum monument found for a comer; Thence, continuing along the said northwest boundary line, S.60' 28' 10" Wto a 7:inch steel rod set for a 120.00 feet corner; Thence, continuing along the said northwest boundary line, N.29'31'50" W., 70.00 feet to aUSFWS aluminum monument found fora oomer; Thence, ontinuing along the said northwest boundary line, S. 60' 27' 07" W ..272.9 feet Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 11 of 28 to a Trinch $eel rod set at ttte south comer ofthe tract herein described: Thence, departing said northwest boundary line oftract 332a with the southwestboundary line of the tract herein described, N. 29" 32'53" W.,255.91 feet to a Trinch steel rod setin the northwest boundary line ofthe said 300-acre reserve for the west comer ofthe tract herein described; Thence, alongthe saidnorthwest boundary line, N.60" 28' 10" E.-765.72feet tothe POINT OF BEGINNING and containing 4.781 acres of land, more or less. Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 12 of 28 SCHEDULE D Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 13 of 28 SCHEDULE D MAP or PLAT RGV Sector/ Hidalgo County Catholic Diocese Of Brownsville Legend Hidalgo County, Texas �.::":":.-:-..;,:_... :ar....v-----=:.:: 5.nf" �.:=-:."".:." .:u.a OOllril!'l.:Ott LAND TO BE CONDEMNED Tract: RGV-MCS-2212 Owner: ROMAN CATHOLIC DIOCESE OF BROWNSVILLE, TEXAS, ACTING BY AND THROUGH ITS BISHOP, THE MOST REVEREND DANIEL E. FLORES, AS BISHOP OF THE ROMAN CATHOLIC DIOCESE OF BROWNSVILLE, AND FOR HIS SUCESSORS IN OFFICE, et al. Acreage: 4.781 * The case caption identifies acreage for the entire parent tract; Access to the entire parent tract may be necessary to complete a survey of the proposed tract outlined in red on the map above. Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 14 of 28 SCHEDULE C Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 15 of 28 SCHEDULE C LEGAL DESCRIPTION Hidalgo County, Texas Tract: RGV-MCS-2217 Owner: ROMAN CATHOLIC DIOCESE OF BROWNSVILLE, TEXAS, ACTING BY AND THROUGH ITS BISHOP, THE MOST REVEREND DANIEL E. FLORES, AS BISHOP OF THE ROMAN CATHOLIC DIOCESE OF BROWNSVILLE. AND FOR HIS SUCESSORS IN OFFICE. et al. Acreage:61.01 As identified in the Warranty Deed, Document#: 1999-814019, recorded on October 12, 1999, in the Deed Records of Hidalgo County and identified in Warranty Deed, Document #: 2011-2219429, recorded on July 1, 2011, in the Deed Records of Hidalgo County. BEGINNING at a Yr:tnch $eel rod set in the southwest right-of-way (R.O.W.) line of FM 494 for the eaS corner of this tract and the north corner of a 72.95acre tract recorded in Volume 1214,Page 1014, Deed Records, Hidalgo County, Toras; Thence, departing said southwest R.O.W. line, with the northwest boundary line of the 72.95 acre tract, S.55" 58 30" W., 823.58 feet to a t/rinch steel rod st for an angle point; Thence, continuing along said northwest boundary line, S.57" l8'38'W., 897.67 feet to a Yrinch steel rod set at the west corner of the said 72.95 acre tract and being in the northea$ boundary line of USA. Tract (326C) as recorded in Volume 1510, Page 87, Deed Records, same being the southwest line of the International Boundary andWater Commission (IBWC) River Levee as recorded inVolume 488, Page 636, Deed Records; Thence, along the southwest line of the IBWC River Levee. the northeast boundary line of U.SA. Tract (326C), N. 30" 31'34" W., 320.68feet Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 16 of 28 to a 7=inch steel rod set for an angle point; Thence, continuing along said boundary lines, N. 29" 38'34" V/.,369.00 feet to a 3-inch *eel pipe with nail found for an angle point; Thence, continuing along said boundary lines, S.60" 2 1'26"W., 125.00 feet To a 7=inch steel rod set for an angle point; Thence, continuing along said boundary lines, N. 30" 23'34" W., 496.50 feet to a 7=inch steel rod set for an angle point; Thence, continuing along said boundary lines, N. 58" 20' 47"E., D4.64 feet to a 7-inch steel rod set for an angle point; Thence, continuing along said boundary lines, N. 31" 22'46" W., 400.00 feet to al/zfirrch steel rod set for an angle point; Thence, continuing along said boundary lines, N. 22" to a 7=inch $eel rod sef y' 46" W ., 457.2O feet for an angle point; Thence, continuing along said boundar5r lines, N. 21" 0l'46, W., to a 733.80 feet 3-inch steel pipe withnail found for an angle point; Thence, continuing along said boundary lines, Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 17 of 28 N. 14" 16'57"W.,222.67 feet to a Yz|nch steel rod set for the west comer of the tract herein described, same being the north comer of IJ.SA. Tract (326C), and the south corner of a 35.8l-acre tract as recorded inVolume Dl4, Page 1014, Deed Records; Thence, along the southeast boundary line of the 35.81 acre tract, N. 79" 32', t0" E., t966.24 feet toa Y-inch $eel rod set in the southwest R.O.W. lineofF.M.494 for the north corner of the tract herein described, same being the east comer of the said 35.81-acre tract; Thence, along the southwest R.O.W. line of FM 494, 5.29" 42' 39" E., 157.A feet to a t/-inch sleel rod found at the point of curvature of a curve to the left having a central angle of 18P 51' 46", a radius of 372.4O, and atangent of 61.86 feet; Thence, continuing along the sourhwest R.O.W. line of F.M. 494 and the arc of said curve to the left, D2.@ feet to a '/-inch steel rod set for the point of tangency; Thence, continuing along the southwest R.O.W. line of F.M. 494, 5.29" 42'39" E., 7853 feet to a t/z-inch steel rod found at the point of curvature of a curve to the left having a central angle of04" 44'23", aradius of 5779.58 feet, and a tangent of 239.19 feet; Thence, continuing along the southwest R.O.W. line of FM. 494 and the arc of said curve to the left, 478.11 feet to a l/u-inch $eel rod set for the point of tangency; Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 18 of 28 Thence, continuing along the suthwest R.O.W. line of F.M. 494, s.34" 27',02" 8., 1,563.00 feet to the POINT OF BEGINNNGand containing 100.900 acres of land, more or less. EXCEPTING A 39.89-acre tract of land situated in Porcion Number 56 and Porcion Number 57, City of Mission, Hidalgo County, Texas, said 39.89-acre tract being part of that called 100.900-acre tract of land known as Tract I described in Special Warranty Deed to Catholic Diocese of Brownsville as recorded in Document Number 814019 of the Deed Records of Hidalgo County, Texas (D.R.H.C.T.), said 39.89-acre tract being more particularly descri bed as follows: BEGINNING at a Yz-ntch iron rod set with yellow plastic cap stamped "HALFF ASSOC." (hereinafter referred toas "with cap") for the North corner of herein described 39.89-acre tract, said point being the intersection of the Southeast line of a tract of land described in Special Warranty Deed to Hunt Valley Industrial I, L.P. as recorded in Document Number 1 153789, Deed Records Hidalgo County, Texas, (previously described asacalled 35.81-acre tract of land described inDeed toAllan Shivers as recorded in Volume l214,Page 1014,Deed Records Hidalgo County, Texas, wi th the common Northeast line ofthe aforementioned 1 00.9OOacre tract and the Southwest right-of-way line of F.M. 494 (a 1O0-foot wide right-of-way), fiom which point a 5/8-inch iron rod found bears N. 29",43',29 W., 5.26 feet; Thence, 5.29', 43', 29" E, with the common Northeast line of said 100.900-acre tract, the Southwest right-of-way line of said F .M. 494 and the Northeast line of the herein described 39.89-acre tract, a distance of 152.28 feet to the point of curvature of a non-tangent circular curve to the left having a radius of 372.40 feet, whose chord bears S. 20", 17' , 36" E., 122.05 feet, from which point a 5/8-inch iron rod found bears 5.29', 43', 29" 8.. 0.21 of a footl Thence, Southerly, continuing with said common line and with said curve, through a central angle of 18", 51', 47", an arc distance of 122.60 feet to the point of tangency, from which point a 5/8-inch iron rod found bears S. 52o, 37', 19" 8., 0.54 of a foot; Thence, S. 29', 43',29" E, continuing with said corrnon line, a distance of 78.53 feet to the point of curvature ofa tangent circular curve to the left having a radius of 5,779.58 feet, whose chord bears S. 32', 05', 4l- E.,477-97 feet, from which point a 5/8-inch iron rod found bears S. 75". 05', 10" W.,0.38 of a foot: Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 19 of 28 Thence, Southeasterly, continuing with said corunon line and with said curve, through a central angle of 04o,44' , 23" , art arc distance of 478.1 1 feet to the point of tangency, from which point a 5/8-inch iron rod found bears N. 85', 53', 43" E., 0.30 of a foot; Thence, S. 34", 27' , 52" E., continuing with said common line, a distance of 448.72 feet to a %-inch iron rod set with cap for the East comer of the herein described 39.89-acre tract, from which point a 5/8-inch iron rod found bears 5.34.,27', 52" 8., 721 .83 feet; Thence, S. 55', 45', 53" W., departing said common line, over and across said 100.900-acre tract and with the South line of the herein described 39.89-acre tract, a distance of 1,237.70 feet to a %- inch iron rod set with cap for the South comer of the herein described 39.89-acre tract, said point being 400.00 feet Northeast of the common Southwest line ofa called 15.58-acre tract ofland described in Easement Deed from County to United States of America (Levees) as recorded in Volume 492, Page 445, Deed Records of Hidalgo County, Texas, the Northeast line of called 247 .68- acl,e tract of land known as Tract 26C described in Warranty Deed to The United States of America as recorded in Volume 1510, Page 87, Deed Records of Hidalgo County, Texas, and the Southwest line of said 100.900 acre tract; Thence, N.31',22',59" W., continuing over and across said 100.900-acre tract, 400.00 feet Northeast of and parallel to said common line and with the Westerly line of the herein described 39.89-acre tract, a distance of 449.20 feet to a %-inch iron rod set with cap for a West comer of the herein described 39.89-acre tract; Thence, N. 22", 34', 59" W., continuing over and across said 100.900- acre tract, 400.00 feet Northeast of and parallel to said common line and with the Westerly line of the herein described 39.89-acre tract, a distance of 420.90 feet to a %-inch iron rod set with cap for a West comer of the herein described 39.89-acre tract; Thence, N. 2l', 01', 59" W., continuing over and across said 100.900-acre tract, 400.00 feet Northeast of and parallel to said common line and with the westerly line of the herein described 39.89-acre fiact, a distance of 705.02 feet to a %-inch hon rod set with cap for a West comer of the herein described 39.89 acre tmct; Thence, N. 14", 13' ,59" W., continuing over and across said 100.900_ acre tract, 400.00 feet Northeast of and parallel to said common line and with the westerly line of the herein described 39.89-acre tract, a distance of 17 1.25 feet to a %-inch iron rod set with cap for the Northwest comer of the herein described 39.g9-acre tract, said point being on the southeast line ofthe aforementioned 35.g r acre tract, from which pointalinchironpipefoundbearsthefollowingtwocalls:5.7g.,44,,17,,W.,a Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 20 of 28 distance of 400.96 feet and N. 140, 13', 59" W., a distance of 88.13 feet; Thence, N. 79', 44', 17" E., with the Southeast line of said 35.81-acre tract. a distance of 1,066.35 feet to the POINT OF BEGINNING. For a total of 61 .01 acres Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 21 of 28 SCHEDULE D Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 22 of 28 SCHEDULE D MAP or PLAT Catholic Dloccs" Of Brownevillc RGV Scctor/ Hidalgo County Leg€nd r I L t €3t,,., \ f,{ 'il [, \ I Hld.lgo County, Tox6 N iP' L. I B Exhibit A LAND TO BE CONDEMNED Tract: RGV-MCS-2217 Owner: ROMAN CATHOLIC DIOCESE OF BROWNSVILLE, TEXAS, ACTING By AND THROUGH ITS BISHOP, THE MOST REVEREND DANIEL E. FLORES, AS BISHOP OF THE ROMAN CATHOLIC DIOCESE OF BROWNSVILLE, AND FOR HIS SUCESSORS N OFFICE, et al. Acreage: 61.01 * The case caption identifies acreage for the entire parent tract; access to the entire parent tract may be necessary to complete a survey of the proposed tract outlined in red on the map above. Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 23 of 28 SCHEDULE E Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 24 of 28 SCHEDULE E ESTATE TAKEN Hidalgo County, Texas Tracts: RGV-MCS-2212 and RGV-MCS-22 I 7 Owner: ROMAN CATHOLIC DIOCESE OF BROWNSVILLE, TEXAS, ACTING By AND THROUGH ITS BISHOP, THE MOST REVEREND DANIEL E. FLORES, AS BISHOP OF THE ROMAN CATHOLIC DIOCESE OF BROWNSVILLE, AND FOR HIS SUCESSORS IN OFFICE, et al. Acreage: 4.781 (RGV-MCS-2212) and 61.01 (RGV-MCS-2217)for atotal of 65.791 The estate taken is a temporary, assignable easement beginning on the date that possession is granted to the United States and ending 12 months later, consisting of the right ofthe United States, its agents, contractors, and assigns to enter in, on, over and across the land described in Schedule C to survey, make borings, and conduct other investigatory work for the purposes described in Schedule B and to access adjacent lands; including the right to trim or remove any vegetative or structr.ual obstacles that interfere with said work; reserving to the landowners, their successors and assigns all rights, title, and privileges as may be used and enjoyed without interfering with or abridging the rights hereby acquired; subject to minerals and rights appurtenant thereto, and to existing easements for public roads and highways, public utilities, railroads and pipelines. Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 25 of 28 SCHEDULE F Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 26 of 28 SCHEDULE F ES SATION OF JUST CO The sum estimated as just compensation for the land being taken is ONE HUNDRED DOLLARS AND NO/l00 ($100.00), to be deposited herewith in the Registry of the Court for the use and benefit ofthe persons entitled thereto; and, an additional sum determined at the conclusion of the temporary estate described damages, ifany. in Schedule E to constitute actual Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 27 of 28 SCHEDULE G Case 7:18-cv-00329 Document 1 Filed in TXSD on 10/25/18 Page 28 of 28 SCHEDULE G INTERESTED PARTIES The following table identifies all persons who have or claim an interest in the property condemned and whose names are now known, indicating the nature of each person's property interest(s) as indicated by references in the public records and any other information available to the United States. See Fed. R. Civ. P. 71.l(c). Interested Party ROMAN CATHOLIC DIOCESE OF BROWNSVILLE, TEXAS, ACTING BY AND THROUGH ITS BISHOP, THE MOST REVEREND DANIEL E. FLORES, AS BISHOP OF THE ROMAN CATHOLIC DIOCESE OF BROWNSVILLE, AND FOR HIS SUCESSORS IN OFFICE P.O. Box 2279 Brownsville, Texas 78522 City of Mission, Texas, a Texas Municipal Corporation 1201 E 8th Street Mission, Texas 7857 ROMAN CATHOLIC DIOCESE OF BROWNSVILLE, TEXAS, ACTING BY AND THROUGH ITS BISHOP, THE MOST REVEREND DANIEL E. FLORES, AS BISHOP OF THE ROMAN CATHOLIC DIOCESE OF BROWNSVILLE, AND FOR HIS SUCESSORS IN OFFICE P.O. Box 2279 Brownsville, Texas 78522 Reference RGV-MCS-2212 October 12, 1999 - Special Warranty Deed-Document# 1999-814019; Deed Records of Hidalgo County RGV-MCS-2212 March 12, 2007 - Lease Agreement RGV-MCS-2217 October 12, 1999 - Special Warranty Deed-Document# 1999-814019; Deed Records of Hidalgo County and July 1, 2011 - Warranty Deed-Document# 20112219429, Deed Records of Hidalgo County Case 7:18-cv-00329 Document 1-1 Filed in TXSD on 10/25/18 Page 1 of 2 Case 7:18-cv-00329 Document 1-1 Filed in TXSD on 10/25/18 Page 2 of 2

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