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)
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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