202238894
EPIPHANY PROPERTIES LLC vs. HALL-WOODS, LISA MARIE
(Court 127, JUDGE RAVI SANDILL)
JUN 28, 2022 | REPUBLISHED BY LIT: OCT 23, 2022
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ORDER DEPOSITING FUNDS INTO REGISTRY SIGNED | 07/13/2023 | |
ORDER GRANTING REIMBURSEMENT SIGNED | 07/13/2023 | |
ORDER SIGNED DISCHARGING RECEIVER | 07/13/2023 | |
ORDER SIGNED GRANTING AGREEMENT PER RULE 11 | 07/13/2023 | |
ORDER SIGNED RELEASING BOND |
Notice of Hearing – Sept. 15, 2023
Jan 31, 2023
It’s a Big Yes and Cheers to Title Deed Fraud by Judge Ravi Sandill.
MOTION FOR EMERGENCY HEARINGS
COMES NOW, Howard Marc Spector (the “Receiver”), and files this Motion for Emergency Hearings on (i) Receiver’s Motion to Extend Receivership and (ii) Receiver’s Motion to Authorize and Confirm Sale of Real Property (together, the “Motions”), and states as follows:
1. On January 31, 2023, the Court entered the Agreed Order Appointing Receiver (the “Receivership Order”), thereby appointing Howard Marc Spector (the “Receiver”) as the Receiver for the real property located at 8506 Clarewood, Houston, Texas 77036 (the “Property”). The Receivership Order set a deadline to automatically terminate the receivership on March 20, 2023.
2. The Motions request the Court’s approval of the Receiver’s sale of the Property and an extension of the term of the receivership to permit the sale to close.
3. During the term of the receivership, the Receiver obtained a contract to purchase the Property, subject to Court approval. Jose Hector Vasquez Tzul and Irma Blanca Vasquez Pacheco (or their assignees, the “Purchasers”) have proposed to pay $375,000.00, an amount sufficient to pay the mortgage and tax debts against the Property and provide significant excess proceeds (i.e. over $100,000) for distribution to the parties.
4. Once a court order is obtained permitting the sale to close, the order must become final and non-appealable before a title insurance policy can be obtained. That will require that the parties wait 30 days from entry of the court order before closing can occur.
5. At the same time, the mortgage lender is not willing to delay foreclosure on the Property, and is able to schedule a foreclosure posting date as soon as mid-April 2023. If the foreclosure is posted, the value of the Property will decrease significantly, and the Purchasers may attempt to secure title to the Property at a lower price through the foreclosure process.
6. Accordingly, the Receiver requests an emergency hearing be set on the Motions during the week of March 27th or the week of April 3rd so that the Property can be sold through the Receiver; so that the Property’s value does not diminish with a foreclosure posting in April; and so the Purchasers are not incentivized to secure title by means of foreclosure.
7. If a hearing is not held on the Motions before April 10, 2023, it will significantly jeopardize the value of the Property and the recovery for parties in interest.
8. No earlier hearing could be requested because the Receiver just received the contract and just recently completed repairs to the Property.
6. For the foregoing reasons, the Receiver requests that the Motions be set for hearing, on or before April 10, 2023.
Dated: March 23, 2023.
By:/s/ Howard Marc Spector
Howard Marc Spector Texas Bar No. 00785023
Spector & Cox, PLLC 12770 Coit Road, Suite 850
Dallas, Texas 75251
Phone: 214-365-5377
Fax: 214-237-3380
hspector@spectorcox.com
RECEIVER
CERTIFICATE OF SERVICE
I hereby certify that on the 23rd day of March, 2023, I caused to be served the Motion upon the parties listed below as indicated.
By:
/s/ Howard Marc Spector
Howard Marc Spector
Jason A. LeBoeuf jason@leboeuflawfirm.com Via email
Michael F. Hord, Jr mhord@hirschwest.com Via email
Lisa Marie Hall-Woods, 307 Hardwick Lane
Pell City, AL 35128
Via First Class Mail
Diane Hall Dent,
191 Whalley A Venue New Haven, CT 06511 Via First Class Mail
Leroy Boyd, Sr.,
20 Cliff Springs Road Springville, AL 35146 Via First Class Mail
Arlene Fern Hall Nasser, 12651 Artesia Avenue #324
Cerritos, CA 90703
Via First Class Mail
Anita R. Hall-Herring, 20 Crystal Lake Drive Sterrett, AL 35147
Via First Class Mail
It appears defendants are resubmitting responses which are either unsigned, not dated or signed and dated showing 9.30.2022. There’s objections to mail delivery of notices not being received in time for the scheduled hearing and similar. In short, it appears they all agree to the house sale, take issue with the appt of the receiver and claim that CCTX’s KP and or his wife, owner of Epiphany are only entitled to 1/7th of the sale proceeds based on the family split of the estate.
The problem LIT foresees is the fact the documents are not signed and dated correctly, which the court, receiver and opposing counsel will hold against the defendants in any order or response.
Blue Window Capital, LLC v. City of Dallas, No. 05-22-00042-CV, at *12-13 (Tex. App. Oct. 17, 2022)
(“ Texas Rule of Civil Procedure 695, which provides: [N]o receiver shall be appointed without notice to take charge of property which is fixed and immovable. When an application for appointment of a receiver to take possession of property of this type is filed, the judge or court shall set the same down for hearing and notice of such hearing shall be given to the adverse party by serving notice thereof not less than three days prior to such hearing.”)
Note; In this case there is ‘agreement’ regarding the appointment, but for reasons explained herein, the reasons are not being performed in good faith.
It’s getting wild now folks. Here we’ve got Christian Consultants of Texas (CCTX) and Kevin Pawlowski scramblin’ to do a deal via Bandit lawyer LeBouef with foreclosure mill lawyer Hord to pay off the liens and sell the home via a receiver so he can get his money out of the home, albeit he has to share a small amount with defendants – who he stole the home from in the first place.
It’s completely appalling when CCTX and Pawlowski should be facing criminal indictment by a grand jury along with the Bandit lawyer(s) involved, including but not limited to, Jason LeBoeuf.
The Pathetic Attempt to Obfuscate the Criminal Entity Known as Christian Consultants of Texas (CCTX)
THE TEN DOLLAR FRAUD IS CHILDLIKE IN EXECUTION
Judge Ravi Sandill is running for an appellate position this election. Make sure you choose your Judges wisely folks. Lawyers are running the State of Texas corruptly and none more so than this Outlaw in a very Dirty Black Robe. #VoteNO.
Epiphany Properties LLC or Christian Consultants of Texas (CCTX), both are owned by Real Scumbags Kevin Pawlowski and his co-conspirator spouse, Roberta L. Pawlowski