Maribel Hill v. Dwight L. Hill

ACCEPTED
15-25-00051-cv
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
8/21/2025 6:22 PM
NO. 15-25-00051-CV CHRISTOPHER A. PRINE
CLERK
FILED IN
15th COURT OF APPEALS
AUSTIN, TEXAS
In The Court of Appeals 15th Judicial District of8/21/2025
Texas 6:22:20 PM
CHRISTOPHER A. PRINE
Austin, Texas Clerk
Originating out of the Court of Appeals 5th Judicial District, Dallas, Texas

IN THE INTEREST OF J.L.H., A CHILD
MARIBEL L. HILL, APPELLANT
Respondent Below

Vs.

DWIGHT L. HILL, APPELLEE
PETITIONER BELOW

Appeal of Judgment in Cause No. DF-22-14398
From the 302 nd Judicial District Court
Dallas County, Texas
Honorable Sandra Jackson, Presiding Judge

APPELLANT MARIBEL L. HILL'S ORIGINAL BRIEF ON APPEAL

Respectfully submitted,

ls/Marisol Lopez
Marisol Lopez
State Bar No. 24050952
301 W. Avenue D
Garland, Texas 75040
972-205-1110 (phone)
1-866-232-2077 (facsimile)
Marisol@lawyerforu.com
IDENTITY OF THE PARTIES

APPELLANT/RESPONDENT: Maribel L. Hill

TRIALANDAPPELLANT COUNSEL: Marisol Lopez
Lopez Law Firm
State Bar No. 24050952
301 W. Avenue D
Garland, Texas 75040
972-205-1110 (phone)
1-866-232-2077 (facsimile)
marisol@lawyerforu.com

APPELLEE/PETITIONER: Dwight L. Hill

TRIAL AND APPELLATE COUNSEL: ORSINGER, NELSON,
DOWNING & ANDERSON, LLP
Richard R. Osinger
State Bar NO. 15322500
425 Soledad, Suite 550
San Antonio, Texas 78205
210-225-5567
richard@ondafamilylaw.com

EPSTEIN FAMIL LAW, PC
5949 Sherry Lane, Ste 1070
Dallas, Texas 75225
Robert D. Epstein
State Bar NO. 24065206
robert@epsteinpc.com
Jordan C. Watson
State Bar NO. 24110895
j ordan@epsteinpc.com
214-692-8200
TABLE OF CONTENTS

IDENTITY OF PARTIES AND COUNSEL ............................................... .i

TABLE OF CONTENTS .................................................................... ii

TABLE OF AUTHORITIES ............................................................... .iv

STATEMENT OF THE RECORD ......................................................... vi

STATEMENT REGARDING ORAL ARGUMENT .................................... vi

STATEMENT OF THE CASE ............................................................ vii

ISSUES PRESENTED ..................................................................... viii

APPEND IX . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix

STATEMENT OF FACTS ................................................................... 1

SUMMARY OF THE ARGUMENT ....................................................... 2

ARGUMENT AND AUTHORITIES ....................................................... 2

I. THE TRIAL COURT ERRED AND ABUSED HER DISCRETION
IN DIVESTING RESPONDENT'S COMPLETE INTEREST IN
DHIA THEREBY CREATING AN UNEQUAL DIVISION OF
THE MARITAL ESTATE . . . . . . . ................................................. .5

A. THE MARITAL ESTATE OVERALL ........................... 5

B. DWIGHT HILL INSURANCE AGENCY, INC ............... 10

1. EVIDENCE IGNORED BY THE COURT ................ 24

C. UNEQUAL DIVISION OF MARITAL ESTATE CAN
EASILY BE REMEDIED ...................................... ... .29

ii
II. THE TRIAL COURT ERRED, MISAPPLIED THE LAW AND
ABUSED HER DISCRETION IN REDUCING THE VALUE
OF RESPONDENT'S EXTENDED TERMINTION
PAYMENTS (RETIREMENT BENEFITS) WHEN A CLEAR
VALUE EXISTED AT THE TIME OF DIVORCE .......................... 31

III. THE TRIAL COURT ERRED AND ABUSED HER DISCRETION
IN DENYING SPOUSAL MAINTENANCE .................................. 36

IV. FOLLOWING A BENCH TRIAL, RESPONDENT TIMELY
FILED HER FINDINGS OF FACT AND CONCLUSIONS OF
LAW AND HER NOTICE OF PAST DUE FINDINGS OF FACT
AND CONCLUSIONS OF LAW. DESPITE AN OBLIGATION TO
DO SO, THE TRIAL COURT NEVER MADE FINDINGS OF
FACT AND CONCLUSIONS OF LAW........................................ 42
V. PRAYER .............................................................................. 44

CERTIFICATEOF COMPLIANCE..................................................... .45

CERTIFICATEOF SERVICE............................................................ .46

iii
TABLE OF AUTHORITIES

CASES PAGE

A.S. v. Texas Dep 1 of Fam. & Protective Servs., 665 S.W.3d 786, 795
(Tex. App.-Austin 2023, no pet.) ........................................................... .4

Berryv. Berry, 647 S.W.2d 945,947 (Tex.1983)......................... 21,32,33,35

Boydv. Boyd, 131 S.W.3d 611 (Tex. App.-Fort Worth 2004) ........................... .3

Cire v. Cummings, 134 S.W.3d 835, 838-39 (Tex.2004).............................. .3,4

Cherne Indus., Inc. V.Magallanes, 763 S.W.2d 768, 772 (Tex. 1989).......... 43,44

Craigv. Craig, 31 Tex. 203,204 (1868) ................................................. 22

Espe, 2021 WL 2021137, at *2 .......................................................... .3,4

Evaristo Gabriel Vazquez V.Jessica Lynn Bailey, No. 03-22-00290-CV at *3
{Tex.App. Apr 25, 2024, no pet.) ......................................................... 3,4

Hancock v. Hancock, No. 2-06-376-CV {Tex.App. 7/31/2007,
No. 2-06-376-CV (Tex. App. Jul 31, 2008) ........................................... 28,29

Landerman v. State Bar of Texas, 247 S.W.3d 426, 430 (Tex. App. - Dallas 2008,
pet denied).................................................................................... 44

Murf v. Murf, 615 S.W.2d 696, 698 (Tex.
1981)........................................................................................ 3,31

In re C.A.S., 405 S.W.3d 373,384 (Tex.App. -Dallas 2013, no pet.) .................. .4

Tenery v. Tenery, 932 S.W. 2d 29, 30 {Tex. 1996)....................................... 44

Sharma vs. Routh, 302 S.W. 3d 355, 360 (Tex.App.-Houston, [14th District]
2009, no petition) ......................................................................... 5, 23

WarrenBaker, JR and Dorris J. Baker vs. Commissioner of Internal Revenue,

iv
No. 02-3262 *5 US Court of Appeals (2003) ....................................... 11, 28

In the Matter of William C. Wade and Frances Carol Wade, 923 S.W.2d 735
(1996) .................................................................................. 12,32,33

Zeifman v. Michels, 212 S.w.3d 582, 588 (Tex. App.-Austin 2006, pet. Denied)... .4

STATUTES
Tex. Fam. Code § 7.001 (Vernon 2006) .................................................... 3

Tex. Fam. Code § 8.051. (Vernon 2006) ......................................... 36,41,42

Tex. Fam. Code § 8.052 (Vernon 2006) ......................................... .36,41,42

Tex. Fam. Code § 8.053 (Vernon 2006) .......................................... .36,41,42

Tex. Fam. Code § 8.054 (Vernon 2006) ...................................... .36,41,42,43

RULES
Tex. R. Civ. P. 297 ........................................................................... 44

Tex. R. Civ. P. 298 ........................................................................... 44

V
STATEMENTOF THE RECORD

The Clerk's Record:

CR P. X = OEC (clerks first record submitted)
SCR P. X = Supplemental Court Record

The Reporter's Record:

TRV2 P. X, Lines X = Volume 2 Trial on the Merits/Exhibits
TRV3 P. X, Lines X = Volume 3 Trial on the Merits/Exhibits
ME P. X, Lines X = Motion to Enter
SME P. X, Lines X = Supplemental Motion to Enter
SRSM P. X, Lines X = Supplemental Record Spousal Maintenance

EX X = main exhibits pulled from record due to large volume of trial exhibits

Respondent is Appellant - wife/mother

Petitioner is Appellee - husband/father.

STATEMENTREGARDINGORALARGUMENT

The Court should grant oral argument because it would give the Court a

more complete understanding of the facts presented by her case, and although this

is not a terribly complicated case, oral argument would allow the Court to better

analyze the legal issues presented by appeal.

vi
STATEMENTOF THE CASE

Nature of the case: This is an appeal from an unequal division of a martial
estate in which Respondent was not awarded one half the
value of the community business, nor was that value
accounted for elsewhere, where Respondent was awarded
a lower value of retirement benefits than what the value
was as of the date of divorce, and Respondent was not
awarded any spousal maintenance though the evidence
showed her to be a stay at home wife and mom for 23
years.

District Court: Hon. Sandra Jackson, Presiding Judge 302 nd Judicial
District Court in Dallas County.

Course of Proceedings: Petitioner, Dwight Hill, filed for divorce because the
marriage had become irreconcilable. Respondent,
Maribel Hill, filed an answer and a counter-petition for
cruelty in the marriage. The child had turned 18 prior to
the divorce.

District Court Disposition: Following a bench trial on June 17th and June 20th of
2024, Respondent, after three attempts, had a motion for
spousal maintenance heard but the Court never issued a
ruling. Respondent and Petitioner had various hearings
regarding the decree and the Court's rulings. The Court
showed much partiality to Petitioner's attorneys and
attempted to create and censor the record to match her
predetermined rulings. This is not unusual as there are
many cases on appeal regarding the 302nd. Respondent
filed requesting Findings of Fact and Conclusions of Law
and the late notice but the Court never issued any
Findings of Fact and Conclusions of Law.

The Court ordered that Petitioner receive 63% and the
wife 37% of the marital community estate, not counting
the reduction of retirement benefits, all which can easily
be remedied by this Honorable Court.

vii
ISSUES PRESENTED

I. THE TRIAL COURT ERRED AND ABUSED HER DISCRETION
IN DIVESTING RESPONDENT'S COMPLETE INTEREST IN
DHIA THEREBY CREATING AN UNEQUAL DIVISION OF
THE MARITAL ESTATE.

II. THE TRIAL COURT ERRED, MISAPPLIED THE LAW AND
ABUSED HER DISCRETION IN REDUCING THE VALUE
OF RESPONDENT'S EXTENDED TERMINTION
PAYMENTS {RETIREMENT BENEFITS) WHEN A CLEAR
VALUE EXISTED AT THE TIME OF DIVORCE.

III. THE TRIAL COURT ERRED AND ABUSED HER DISCRETION
IN DENYING SPOUSAL MAINTENANCE.

IV. FOLLOWING A BENCH TRIAL, RESPONDENT TIMELY
FILED HER FINDINGS OF FACT AND CONCLUSIONS OF
LAW AND HER NOTICE OF PAST DUE FINDINGS OF FACT
AND CONCLUSIONS OF LAW. DESPITE AN OBLIGATION TO
DO SO, THE TRIAL COURT NEVER MADE FINDINGS OF
FACT AND CONCLUSIONS OF LAW.

viii
APPENDIX
EX A: Wife's Amended Property Division
EX B: State Farm Termination and Extended Termination Payments Valued
as of June 20, 2024, Attached to Exhibit C (Divorce Decree)
EX C: Divorce Decree
EX D: Current Mortgage on Elsby (Respondent's Separate Property Which Is
Paying Mortgage on 1211 Velasco)
EX E: Elsby Mortgage Prior to Marriage ($ 78,527) With a Water Claim
Being Paid of$ 83,583.52, Made Prior to Marriage
EX F: Fuqua Report Valuing Business at$ 728,000 as of 2022
EX G: Restore Agreement - Community Joint Venture
EX H: DHIAArticles of Incorporation
EX I: Note Showing Respondent as Vice President of DHIA
EX J: DHIA/State Farm Contract
EX K: Tax Return Showing Sample K-1
EX L: Tex. Fam. Code § 7.001 (Vernon 2006)
EX M: Tex. Fam. Code§ 8.051. (Vernon 2006)
EX N: Tex. Fam. Code§ 8.052 (Vernon 2006)
EX 0: Tex. Fam. Code§ 8.053 (Vernon 2006)
EXP: Tex. Fam. Code§ 8.054 (Vernon 2006)
EX Q: Tex. R. Civ. P. 297

EX R: Tex. R. Civ. P. 298

ix
STATEMENT OF FACTS

On June 17th and 24 th, 2024, a non-jury trial took place in the matter of Hill

vs. Hill. The parties were married from October 19, 2001 to June 20, 2024. (CR P.

85, 99) Final rulings were rendered on December 10, 2024. (CR P. 99) Respondent

timely filed her request for Findings of Fact and Conclusions of Law (FFCL) (CR P.

113-118) and timely filed her past due notice of FFCL (CR P. 164-166) FFCL were

never filed by _theCourt. The trial Court, successfully and unsuccessfully, sought to

craft the record to fit her predetermined rulings of divesting Respondent of her share

of Dwight Hill Insurance Agency, Inc (DHIA), (TRV3 P. 92, lines 19-22), spousal

support (TRV3 P. 102, lines 2-21 ), and oflowering the value of her future retirement

benefits, the most valuable assets of the marital estate. 1 (TRV3 P. 7, lines 17-25 &

P. 8, lines 1-16, P. 72, lines 18-19; TRV2 P. 180, lines 1 - P. 186, line 9, as some

examples) Petitioner was allowed to provide long winded answers while

1
TRV3 P. 7, lines 17-22 - Maribel Hill testimony - Q: "So the property at Fort Velasco, right
now, there's a house on that property, true? A: That's flooded right now, yes. Q: Objection,
nonresponsive. A: yes Court: sustained" Q: It's got a house.." Court: "Mrs. Hill, he's going to ask
you questions."; P. 8 line 6 "Don't add anything else."; P. 8 line 10-14, Ms. Lopez: "Objection,
Your Honor. I asked questions to Mr. Hill he added a lot of other things. The Court: "And I
object---listen, don't your start with me. Sit down." Ms. Lopez: "I'm just objecting, your
Honor."; P. 72, lines 17-20 Ms. Lopez: "How long have you been a stay at home mom and wife?
A: Almost 23 years. Q: And were you allowed to work outside the home? The Court: okay.
That's redundant, Counsel. She's said it before."

1
Respondent's testimony was limited. (TRV2 & TRV3) Petitioner received 63% of

the marital estate and Respondent received 37% of the marital estate.

SUMMARY OF THE ARGUMENT

The trial Court committed reversable error, abused her discretion,

misapplied the law, did not understand some of her own rulings when she rendered

an unequal division of the marital estate in favor of Petitioner. The court

misapplied the law, and did not understand her own ruling, when she reduced the

value of Respondent's share of the future retirement benefits, known as extended

termination payments, to be received by Respondent as, if and when received by

Petitioner. The Court abused her discretion and committed clear error by divesting

Respondent of$ 364,000, her share of the value of the marital estate community

business, DHIA, without equalizing Respondent's share elsewhere. The Court

abused her discretion in not awarding Respondent, a stay-at-home wife and mother

of twenty-three (23) years, who has been denied one job after the other, any

spousal maintenance and left her without any income. Respondent is living off of a

retirement account that charges penalties and taxes every time money is pulled out

and said account will soon be exhausted.

ARGUMENT

2
A trial court is charged with dividing a community estate in a "just and

equitable" manner, considering the rights of BOTH parties. Tex. Fam. Code§ 7.001

(Vernon 2006). A trial court's division of a martial estate is reviewed for an abuse

of discretion. Murf v. Murf, 615 S.W.2d 696, 698 (Tex. 1981). "A trial court abuses

its discretion if it acts without reference to any guiding rules and principles such that

the ruling is arbitrary or unreasonable." Espe, 2021 WL 2021137, at *1 (Citing Cire

v. Cummings, 134 S.W.3d 835, 838-39 (Tex.2004); Evaristo Gabriel Vazquez V.

Jessica Lynn Bailey, No. 03-22-00290-CV at *3 (Tex. App. Apr 25, 2024, no pet.)

In determining whether the trial court abused its discretion by deciding an issue

without sufficient support, the court uses a two pronged inquiry: ( 1) did the trial

court have sufficient evidence upon which to exercise its discretion and (2) did the

trial court err in its application to that discretion. Boyd v. Boyd, 131 S.W.3d 611 (Tex.

App. - Fort Worth 2004) The division need not be equal, and an unequal division

will be upheld on appeal so long as a reasonable basis exists for it. Muri, 615 S.W.

2d 696, 698, 699 (Tex. 1981). In exercising its discretion in dividing the estate, the

trial court may consider many factors, commonly known as the "Murf factors,"

including, but not limited to, the nature of the property, the disparity of incomes or

earning capacities, the parties business opportunities, the parties relative financial

condition and obligations, the parties education and physical condition, the benefit

the innocent spouse would have received had the marriage continued and the

3
probable need for future support. Id. at 699; In re C.A.S., 405 S.W.3d 373,384 (Tex.

App. -Dallas 2013, no pet.)

The abuse of discretion standard overlaps with traditional sufficiency standard

of review in family law cases. Evaristo, No. 03-22-00290-CV at *3 (Tex. App. Apr

25, 2024, no pet.).; Zeifman v. Michels, 212 S.w.3d 582,588 (Tex. App.-Austin 2006,

pet. Denied) Challenges to legal and factual sufficiency do not constitute

independent grounds for asserting errors but are instead relevant factors in

determining whether the trial court abused its discretion. Evaristo, No. 03-22-00290-

CV at *3 (Tex. App. Apr 25, 2024, no pet.); Espe, 2021 WL 2021137, at *2 (Citing

Cire, 134 S.W.3d 835, 838-39 (Tex.2004) "Evidence is legally sufficient when it

would enable reasonable and fair minded people to reach the verdict under review

and is factually insufficient only if it is so contrary to the overwhelming weight of

the evidence as to be clearly wrong and unjust." Evaristo, No. 03-22-00290-CV at

*3 (Tex. App. Apr 25, 2024, no pet.); A.S. v. Texas Dep 1 of Fam. & Protective Servs.,

665 S.W.3d 786, 795 (Tex. App.-Austin 2023, no pet.) "A trial court does not abuse

its discretion if there is at least some substantive, probative evidence that "exists to

support the trial court's decision." Evaristo, No. 03-22-00290-CV at *3 (Tex. App.

Apr 25, 2024, no pet.); Espe, 2021 WL 2021137, at *2 (Citing Cire, 134 S.W.3d 835,

838-39 (Tex.2004). "To convince this court to disturb the trial court's division of

property, Timothy must show the trial court clearly abused its discretion by a

4
division or an order that is manifestly unjust and unfair." Sharma vs. Routh, 302

S.W. 3d 355, 360 (Tex. App.-Houston, [14th District] 2009, no petition). The Court's

division was manifestly biased, unjust, against the weight of the evidence, unfair,

clear error, misapplication of law and had no reasonable basis to render an unequal

division of a LARGE estate in favor of Petitioner. Fair minded reasonable people

would never reach such an unfair verdict.

Respondent hereby incorporates all paragraphs together within this brief as

much is interrelated.

I. THE TRIAL COURT ERRED AND ABUSED HER DISCRETION IN
DIVESTING RESPONDENT'S COMPLETE INTEREST IN DHIA
THEREBY CREATING AN UNEQUAL DIVISION OF THE MARITAL
ESTATE

A. THE MARITAL ESTATE OVERALL

The community estate had total assets of approximately $ 3,046,898 (EX A;

TRV3 P. 133-140), excluding future retirement benefits (termination and extended

termination payments), agreed children's distributions, deemed separate property

nor small personal property with unsupported values, such as jewelry, guns, and used

furniture. Community assets awarded to the Petitioner was $ 1,918,203.50 and to

Respondent was$ 1,128,694.50, a 63/37 split. Had Respondent received her share

of DHIA, the correctly characterized community property business (TRV3 P. 88,

lines 8-10), Petitioner would have received 51% of the community estate and

5
Respondent 49%, a more equal division. Of course, the future retirement benefits

are not in play in this breakdown. The breakdown is as follows (EX A & EX C):

1) Real property (beach property= Velasco & Nesmith (5 lots on Nesmith)

$961,000.00 - $ 265,000.00 (Velasco) = $ 696,000.00 total

Velasco's mortgage rests on Elsby (EX D; TRV3 P. 39, Lines 11-25, P. 40

- P. 41, Lines 1-5, P. 174-187), Respondent's separate property. (TRV3 P.

85, Lines 23-25) Of note, during the bench trial, Velasco and all beach

property was being inundated by the current hurricane. Petitioner

continuously leveraged Elsby (TRV3 P. 38, lines 24-25, P. 39 - P. 41, line

11) to acquire beach property free and clear of loans. Petitioner benefited

from this strategy because all property he received is free and clear of

loans. Petitioner, knowing he was going to file for divorce, paid off

everything, including all vehicles, and left Respondent's separate property,

Elsby, she and her college kids need to live in, with a hefty mortgage. (EX

A & D) This makes Velasco a wash and not a credit to Petitioner. Elsby's

mortgage is now three times higher post marriage. (TRV3 P. 156-160, EX

E) Elsby had a $ 78,522 mortgage on it, prior to marriage, and was being

paid$ 83,583.52 for a claim that originated, prior to marriage, to repair the

downstairs. (TRV3 P. 37, lines 18-25, P. 38, lines 1-2; EXE) The insurance

company paid the contractors as they repaired the home. (TRV3 P. 38, lines

6
3-5) Within months of marriage, Petitioner began leveraging the property

by refinancing it over and over in order to gain cash to buy other properties.

(TRV 3 P. 38, lines 24-25, P. 39 lines 1-7; EX E) Upon divorce, Elsby is

the only asset encumbered, and since the Court wrongfully divested

Respondent of her share of the income of the community business (TRV3

P. 92, lines 2-21), though she agreed fifty percent (50%) of the business

income belonged to Respondent,2 and denied spousal maintenance (TRV3

P. 102, lines 2-21), Respondent cannot qualify to assume the now higher

mortgage herself. With that, the Court ordered Respondent to sign the

Assumption Deed of Trust, attached to the decree (EX C), as of September

15, 2025 (SME p. 31, lines 18-25, P. 32-P. 40, line 11), which was not

only not a ruling at trial (TRV3 Pg. 85-111), this places a lot of power on

Petitioner to acquire Respondent's separate property home if she misses a

single payment. Respondent signing said assumption to her separate

property home is injustice when the Court divested Respondent's interest

in DHIA and no spousal maintenance, leaving her without an income, after

being a stay at home wife and mother for twenty-three (23) years, making

it impossible for Respondent to assume the mortgage alone, and when the

2
TRV3 P. 89, lines 11-12 The Court: "It is the income of the business that's community property.
That's why the Court said on that it's 50/50."

7
Court could have ordered the home be paid off like all the other property

was. The Court's impartial rulings and unequal division of the marital

estate is leading to a once wealthy woman's indigency, which was not

necessary, being that the value of the estate was several million dollars and

the community business earns close to $ 500,000 per year. Insurance

premiums only continue to rise.

107 Nesmith, known as the three beachfront buildable beach lots, valued

at $546,000, was ordered to be sold, and wife not be allowed to be the

broker. (TRV3 P. 86, LINES 8-16) The split was ordered as 35% net to

Petitioner and 65% net to Respondent to offset the whole life policy's ALL

being awarded to Petitioner. (TRV3 P. 102, lines 9-21) The Court lowered

the recovery of the property because 6% must be paid to a realtor, and

Respondent, holding a real estate license, could have saved 3% of the

realtor fees and/or gained some income.

Total to Petitioner: $ 75,000 (123 Nesmith) + 191,100 (pre-net of 107
Nesmith) = $266,100

$ 75,000 + $ 141,414 (net)= $216,414

Total to Respondent:$ 75,000 (118 Nesmith)+ 354,900 (pre-net of 107
Nesmith)=$ 429,900

$ 75,000 + $ 262,626.00 (net)=$ 337,626.

8
Unfortunately, 107 Nesmith remains for sale. (SRSM P. 9, lines 22-25 &

P. 10, lines 1-21) With high interest rates and the real estate market in a

sludge, beach properties are not moving. Should the Court allow any

receivership, to sell the lots, in the future, this will increase the unequal

division of the estate as Petitioner has already received all of the whole life

policies without any taxes or penalties.

CASH AND FINANCIAL ACCOUNTS

Petitioner - $ 90,579.50. Petitioner previously received his $ 52,742.00

(TRV3 P. 87, lines 20-22)

Respondent- $ 66,099.50 (this lasted about 6 months as Respondent's

minimum bills are $ 10,000 per month (TRV3 P. 51, lines 13-16, SCR P.

232-236; SCR P. 20-22)

2) CLOSELY HELD BUSINESS INTERESTS

Petitioner - $ 728,058.50; DHIA valued at $ 728,000.00 based on net

income (TRV2 P. 194, Lines 1-5 and 21-25, P. 195, lines 1-19, P. 1129-

1140, EX F P. 7) + $ 117/2=$ 58.50

Respondent - $ 602.50; Restore Entertainment - $ 544.00 + $ 117/2=$

58.50. Restore was a community joint venture (TRV3 P. 26, lines 18-23,

P. 42, lines 24-25, P. 43, lines 1-14; EX G, TRV3 P. 346) that never

generated income. The court's ruling is unclear as to whether she is

9
deducting, adding or neither Petitioner's claimed $ 89,502 he unfairly

wants credited to the wife as an asset she received when it was a

community venture and Restore has no worth. {TRV3 P. 43, lines 7-8, P.

88, lines 2-4; EX A & G)

3) RETIREMENT ACCOUNTS

Petitioner-$ 604,886.50

Respondent - $ 605,592.50

4) MOTOR VEHICLES

Petitioner - $ 22,600.00

Respondent - $26,500.00

5) MISCELLANEOUS ASSETS

The court did not assign values to these items on spreadsheet as no

evidence/appraisals existed and each was awarded what they had in their

possession. {TRV3 P. 95, Lines 2-11)

6) INSURANCE - Whole Life Policies

Petitioner - $ 203,538 (TRV3 P. 95, lines 21-24)

Respondent - $ 0.00

B. DWIGHT HILL INSURANCE AGENCY, INC. (DHIA)

DHIA opened after marriage. {TRV3p. 363-364, EX H) Respondent was fifty

percent (50%) shareholder on the K-ls {TRV3P. 44, lines 17-25, P. 45, lines 1-3, P.

10
375, EX K) and reflected as a co-owner on loans (TRV3 P. 790-792, EX.I) as well,

though Petitioner controlled all the money. (TRV3 P. 45, lines 6-7) Respondent was

on the K-ls as fifty percent (50%) shareholder every year. (TRV3 P. 365 -788)

Respondent was not allowed to have a credit card in her name until Restore was

opened. (TRV3 P. 45, lines 8-13)

Though the Court correctly characterized (DHIA) and the income it generated

as community property with a fifty-fifty (50/50) split (TRV3 P. 89, lines 6-12), she

later stated she was talking about termination payments (TRV3 P. 89, lines 18-23)

and refused to award Respondent fifty percent ( 50%) of the actual value of DHIA.

This does not make sense since she clearly stated, "The next distribution, under the

businesses, would be to .... ", indicating she had moved on to the next subject, which

was DHIA, after completing termination payment rulings. (TRV3 P. 89, lines 22-25

& P.88, lines 11-25) The Court erroneously misapplied the law if she treated the

termination payments as one half the value ofDHIA. Had the Court issued findings

of fact and conclusions of law the reason would be known. In fact, Fuqua did not

consider the termination payments when valuing the business at $ 728,000.00.

(TRV2 P. 193, lines 19-25) Termination payments are not for the sale of the business 3

3
Warren Baker, JR and Dorris J. Baker vs. Commissioner of Internal Revenue, No. 02-3262 *5
US Court of Appeals (2003)

11
but are instead deferred compensation to be divided upon divorce. 4 Termination

payments are income to be divided upon retirement or termination, if, as and when

received, to incentivize an agent to not become State Farm's competitor, but is

nevertheless, not the VALUE of the business. Alternatively, the Court abused her

discretion and followed Petitioner's cues, like head movements (TRV3 P. 91, lines

5-6), eye contact or just straight words into the record, that occurred throughout the

trial, to render that manifestly unjust and clearly wrong lack of award of the value

ofDHIA that no reasonable person would have done.

Moreover, the Court undoubtedly turned a deaf ear to the $ 728,000 valuation

ofDHIA by Mr. Fuqua, claiming she didn't hear said valuation. (TRV3 P. 89, lines

24-25 & P. 90, lines 1-18) When asked if she was going to award zero dollars to the

wife of the community business earning about half a million a year (TRV3 P. 90,

lines 22-25), she said she didn't say that (TRV3 P. 91, line 2), yet in the end that is

exactly what she did (Ex C) Petitioner, upon hearing the trial court was not going to

award zero dollars to Respondent for the community business, guided the Court on

how to repair the award of "50% income" to the wife, alleging she was referring to

termination payments. (TRV3 P. 91, lines 1-25)

4
In the Matter of the Marriage of WilliamC. Wadeand Frances Carol Wade,923 S.W.2d 735
(Tex. App.-Texarkana, 1996, no writ)

12
The Court then stated the "expert said the business can't be sold." (TRV3 P.

91, lines 20-23) Notice how the court reiterated for the record, during trial, with Mr.

Fuqua, the NON State Farm expert, that, he BELIEVES the agency cannot be sold.

(TRV2 P. 199, lines 1-3, The Court: "Sir, one question from the Court. Am I hearing

you say that a State Farm Agency cannot be sold?" Fuqua: "Not that I'm aware.")

Fuqua does not know for sure whether the agency can be sold or not and has admitted

that it could be sold with State Farm permission.

The Court certainly did not clarify his valuation of$ 728,000 for DHIA nor

that he admitted the contract that applies in THIS divorce says it can be sold with

State Farm permission. (TRV2 P. 186, lines 24-25 & P. 187, lines 1-6) Notice the

Court also did not reiterate for the record that Mr. Fuqua admitted he is NOT a State

Farm expert, has never worked for State Farm and is deriving all of his information

from Petitioner, himself. (TRV2 and TRV3) Though the Court, when necessary,

treated Fuqua as a State Farm expert to justify her impartial rulings (TRV3 P. 92,

lines 12-15), in a different occasion, she admitted that there was NO State Farm

expert testimony. (TRV3 P. 107, lines 6-7) Nonetheless, the Court, though she stated

she didn't HEAR Fuqua value the business, she later stated" ... and he objected to

that ... " (TRV3 P. 90, lines 9-10), when Respondent said he testified to the valuation

as$ 728,000.00. (TRV3 P. 89, lines 24-25 & P. 90, line 1) Clearly, the Court heard

the valuation. In fact, the Court also stated, "Based on what you did preliminarily

13
then what Mr. Orsinger did not do, and then when you did what you did, Mr.

Orsinger was given latitude by the Court to give value." (TRV3 P. 90, lines 11-14)

What Respondent "did" was object to the report as hearsay, at the time that it was,

at the beginning of trial (TRV2 P.184, lines 23-25; P. 185, lines 1 - 25; P. 186, lines

1-23) and questioned Fuqua on the report after the foundation was appropriately laid.

(TRV2 P. 188, lines 19-25; P. 189, lines 1-25; P. 190, lines 1-25; P. 194, lines 1-5)

What Petitioner "did not do" was purposefully not question Fuqua on the value of

the business, so there would not be evidence in the record as to the value, because

the Court had struck Respondent's accountant expert, Vantarakis. (TRV2 P.154,

lines 23-25) If there is not a value in the record, then the Court doesn't have a hard

number to use in awarding Respondent her fifty percent (50%) interest in DHIA.

Petitioner did not anticipate that Respondent had cross designated Fuqua, so

after much discussion with the Court, Respondent was finally able to question Mr.

Fuqua on the value he had rendered for DHIA but was prevented from fully

developing said valuation because the Court made Respondent "yield her time"

(TRV3 P. 179, lines 23 - P. 190, line 20) to return Fuqua to Petitioner to

"rehabilitate" him in the manner that he needed to (TRV2 P. 180, lines 1 - P. 186,

line 9), when Petitioner continued.to inappropriately object to Respondent being able

to question Fuqua on the value. Petitioner had the opportunity to question Fuqua on

the value, after laying the appropriate foundation, and prior to Respondent's

14
questioning of Fuqua, but deliberately chose not to. Please read pages 180 through

186 of TRV2, though other areas of the transcript evidence such as well, to see the

level of impartiality exhibited by the Court in favor of Petitioner and the aid

Petitioner received from the Court to prevent the value of the business from entering

the record. Respondent had the right and responsibility to object to an expert report

as hearsay until the expert was on the stand and a foundation laid. The Court used

Respondent's objection to the hearsay document, appropriately made at the

beginning of trial, to try to censor the record on the value of the business since

Petitioner's goal was to exclude said value. It is evident in these pages that the Court

was figuring out how Petitioner wanted her to rule so she could comply. Why would

any Judge ask one party if it was THEIR intention to admit a produced trial exhibit

or not and then exclude it based on THAT party's intention instead of on whether

the document was authenticated by the expert and now admissible? This is clear

impartiality and cannot be allowed in our Court system, especially family law courts

where families' livelihoods are at stake. Real families whose lives are being turned

upside down by a divorce are in desperate need of our Courts to be impartial, fair

and to divide an estate in a just, right and fair manner and protect the well-being of

ALL parties in the process.

As a result of more partiality, Respondent was cut short of her attorney

questioning her and developing what she needed to develop in regards to abuse,

15
health issues and earning capacity, in addition to being censored in questioning

Fuqua. When the Court was trying to figure out whole life policies, the Court stated

she didn't hear certain evidence and Respondent's attorney stated, "Because I got

cut short." (TRV3 P. 97, lines 21-22) The trial court responded "You didn't get cut

short. You ran out of time." (TRV3 P. 97, lines 23-25) The record reflects how much

time Respondent had for her attorney to develop her side of the case and how much

time Petitioner had to develop his case. Please see the Offer of Proof for all the

evidence Respondent was purposefully not given time to offer. (TRV3 P. 81, lines

24 - P. 84, line 19) This is impartiality, at best. Nonetheless, following Petitioner's

leading questions to Fuqua making him testify as if he is completely incompetent

and didn't know what he was doing when he rendered a valuation of the business

(TRV3 P. 190, lines 23 -P. 192, line 20), Respondent, on redirect, was able to obtain

the value of the business on the record. Fuqua testified the value of DHIA in 2022

was $ 728,000, and testified to the method he employed to derive at such valuation.

Notice Fuqua testified that the valuation of$ 728,000, did not have anything to do

with the termination payments because he testified that they were not considered in

the valuation, as they should not have been. See as follows:

TRV2, P.193, line 3 -25 (Fuqua Testimony)

Q. So you're telling me that you did not have the State Farm Agreement when
you rendered this opinion because you just testified earlier with me that you
did?

16
A. We did not consider the State Farm Agreement nor the termination
payments when we came up with that valuation.

Q. And how many years have you been doing this?

A. Twenty-five or 30.

Q. And how many divorce cases have you testified in?

A. Over a hundred.

Q. And do you normally not read the agreement that they have, though it's
been provided to you, and you provided it as one of the things that you
reviewed, prior to rendering your analysis of what you felt the business was
worth?

A. No, we read it.

Q. So you did read it?

A. Yes.

Q. Okay. And so, all of the documents that were provided that you said you
looked at that you reviewed when you rendered the $728,000 that you stated
in your report that you reviewed, you did consider when you made your
evaluation of $728,000, true?

A. Not as it being freely transferable and not with respect to the termination
payments. We did not consider that.

TRV2, P. 194, lines 1 - 25 (Fuqua Testimony)

Q. Okay. Here's where I would like some help if you don't mind. I do not
understand if the value is $748,600 based on 2022 or if it's $728,000?

A. 728,000. We used the capitalization of earnings met. We did not use the
market data method.

17
Q. Okay. And when you did this analysis, on Report 002857, okay, it was
based on earnings of $331,790 and in 2019, $329,888, 2020, 335,274, '21,
371,474 '22, correct? This is your report.

A. Incorrect.

Q. Incorrect. So what did you use these numbers for-

A. You're confusing the term revenues and the term income.

Q. Okay. So in your total revenues, these numbers were part of your analysis,
true?

A. True.

Q. And in 2023, have you seen that tax return?

A. I have.

Q: And how much was that?

A: As I sit here today, I cannot recall.

Q: So let me just show you that it is $438,000 for 2023.

A: The revenues?

Q: 1120, yes.

A: We look at the net income. We don't go into the revenues.

TRV2, P. 195, lines 1 - 10 (Fuqua Testimony)

Q. That would certainly not decrease a 728,000 dollar value, true?

A. Would you mind moving it up so we can see what the net income shows of
154,000?

Q. Yeah

18
A. That's the number that we would frequently use in trying to come up with
our capitalization earnings method.

Q: Okay. Which you did the same thing, right, for these years?

A. Correct.

TRV2, P. 188, lines 4-8 (Fuqua Testimony)

Q. Okay. But you did provide a list of insurance agents that have sold their
business, true?

A. I do believe that, in most of our valuation reports, we include some
comparable's, if we can find them, similar companies that have been sold, yes.

TRV2, P. 195, lines 14-19 (Fuqua Testimony)

Q. When you do a valuation of a business, do you normally account for when
somebody lives through the business?

A. Yeah, we try to consider any kind of personal expenses that were paid out
of the business.

Q. And did you do that when you did this report?

A. Probably not to the extent that you would like us to.

Fuqua valued the business for $ 728,000, in 2022, with comparable, after

reviewing the specific contract between DHIA and State Farm, looking at the

revenue and income after considering personal expenses, and that report was to be

used at trial as a number in which to award Respondent her share of the value of the

business. All businesses have a value and this business should have been divided

fifty-fifty (50/50). Of note, Fuqua did not update the valuation (EX F) as the earnings

consistently increased, making the business likely worth more. {TRV2 P. 194, Lines

19
21-22) In reality, Petitioner would only have been giving Respondent less than one

year's income on a business he will continue to earn almost half a million dollars on

for years to come, making $ 364,000, not exactly a fair award either. The income

that will continue to be made, after marriage, came from the renewal of premiums

derived during the marriage. Had Petitioner not filed for divorce, Respondent would

have benefited from the continued earnings of the community business and would

not be in financial distress.

Though Fuqua was qualified to conduct a business valuation based on the

revenue and income earned, he was and is not qualified to make decisions on whether

State Farm would allow the servicing of policies by DHIA to be sold or assigned to

another agent for a profit. A reasonable person would not believe that he could make

such decision when he stated he was not a State Farm expert, not a State Farm

representative and that he derived the information from Petitioner (TRV2 P. 172,

lines 8-15) and when he admitted the contract says it can be sold with State Farm's

permission. Nevertheless, the court would use the terminology, "the expert said",

to attempt to justify her predetermined rulings regarding whether DHIA could be

sold and how to calculate the value of the percentage for the extended termination

pay, the two biggest disputed items in this divorce. Yet, the Court made clear when

discussing termination payment values that there was NO State Farm expert. (TRV3

P. 107, lines 6-8, THE COURT: Unless you-all brought an expert in from State

20
Farm, which you did not, then the Court would have a hard number but we don't.")

The Court is incorrect that a hard number does not exist and erred because State

Farm gave the hard number on the value already earned as of the date of divorce as

$ 6,888 for termination payment and$ 6,816 for extended termination payment. (See

Exhibit B)

The ONLY State Farm evidence, before the Court, was the contract between

State Farm and DHIA stating State Farm can give permission to sell or assign DHIA

and the values earned, as of the date of divorce, for termination and for extended

termination payments, all directly from State Farm. While Fuqua could value the

business, Fuqua could not change the terms of the contract between State Fann and

DHIA. While Fuqua could read the value of the termination and the extended

termination payments, already placed by State Farm themselves, as of the date of

divorce, on State Farm's document (Exhibit B), Fuqua cannot change the terms of

the already earned value. In fact, an expert is not needed to know the value of the

termination and extended termination payments because all one has to do is read

State Farm's document, EX B. This document does not require expert knowledge.

Fuqua also cannot change Berry which states retirement benefits are to be valued as

of the date of divorce AS IF ELIGIBLE TO RETIRE. Berry v. Berry, 647 S.W.2d 945,

946 (Tex.1983) Expert testimony is not needed to read or understand: "The

following are your estimated monthly termination and Extended Termination

21
Payments by company assuming a 5/31/2024 termination date ..... Term Pay $ 6,888

and Ext Term Pay$ 6,816." (EX B) Without question, the already earned amount as

of the date of divorce, was known at the time the divorce decree was signed. This is

clear error, misapplication of the law, unjust, against the great weight of the

evidence, and so manifestly unfair that it is just plain wrong.

The Court divesting Respondent/wife of ALL of her community interest in

DHIA (TRV2 P. 179, lines 23-25 - P. 186, line 9, P. 188, lines 16 - P. 190, line 20,

P. 199, lines 1-3), without any equalization, is an abuse of discretion. 5 The Court,

after Petitioner's million inappropriate objections to Respondent questioning Mr.

Fuqua of the DHIA valuation, though perfectly appropriate to do so, told

Respondent, right as Respondent was starting to question Fuqua on the valuation of

the business, "Ms. Lopez, you 're going to yield your time. Sit down" (TRV2 P. 190,

lines 17-18) and passed Fuqua back to Petitioner to undo his testimony. Respondent

was in shock, paralyzed, at the level of abuse of power, the level of impartiality and

complete disregard for the rule of law. Respondent's counsel has never seen such

blatant bias at a trial before. Though partiality and hostility has been the norm with

this Court, this level of impartiality was not fathomable. The Fifth Court of Appeals

5
Craig v. Craig, 31 Tex. 203, 204 (1868) (finding abuse of discretion when trial court's property
division divested one party of "all his property".

22
has countless appeals regarding this Court. (See Court of Appeals 5th District) Clear

abuse of discretion and of power.

The Court, the morning of trial, excluded Alex Vantarakis, Respondent's

accountant expert who agreed with Fuqua's $ 728,000 valuation of DHIA up to year

2022. (TRV2 P. 148, line 24-25 & P. 152, line 23; TRV3 P. 84, line 14-18)

Accordingly, Petitioner, with the aid of the Court, changed his trial strategy to

exclude the business valuation, altogether, and argue 'the business cannot be sold"

(TRV2 P. 180, lines 15-21, P. 181, lines 23-25, P. 182, line l,P. 190, lines 1-5),

arguing that Respondent receives zero of her interest in the business.

Nonetheless, the Court not dividing the$ 728,000 value allowed Petitioner a

windfall of$ 364,000.00, that unequivocally belongs to Respondent. This is clear

error. Sharma vs. Routh, 302 S.W. 3d 355, 360 (Tex. App. -Houston, [14th District]

2009, no petition) The estate was large enough to, at a minimum, assess that value

elsewhere. For instance, the Court could have awarded all three beach front lots, 107

Nesmith, to Respondent to equalize the value of the business, instead of a 35%/65%

net profit split, which was made to equalize Petitioner receiving all of the whole life

policies. With that said, Respondent needs income so a buyout would have allowed

Respondent income to live on while still allowing Petitioner a large income as well.

23
Fuqua, was paid a minimum of$ 8,000.00 {TRV2P. 174, line 24) to value the

business and he testified that he took various factors, such as income and revenue

into account when assessing the value. (TRV2 P. 194, lines 14-16, 24) Fuqua would

not have been hired to conduct a business valuation if DHIA did not have a value to

divide upon divorce.

1. EVIDENCE IGNORED BY THE COURT

a. DHIA/State Farm contract states under Section VI (B):

" ..... and no right in any sum due or to become due to the agent

hereunder can be sold, assigned, or pledged without the prior written

consent of the Companies." {TRV2 P. 461 - 472, EX J) Clearly, an

agency can be sold to another State Farm agent with State Farm

perm1ss1on.

b. Fuqua admits he read the contract prior to rendering his report. (TRV2

P. 193, Line 12-18)

c. Fuqua's valuation of$ 728,000. (EX F and prior paragraphs)

d. Fuqua's admission that the contract states the agency can be sold with

State Farm permission. See Fuqua's testimony TRV2 P. 186, lines 24 -

25 and TRV2 P. 187, lines 1-9:

24
Q. And you testified today that an insurance agency that is contracted

with State Farm is unable to be sold or assigned, true, to anyone?

A. Not without State Farm's permission that is correct.

Q. So with State Farm's permission, then it can be assigned?

A. Conceptually, if State Fann were to agree to it, I guess that it could.

Like I said, because of the termination payments, being so lucrative, no

one would want to jeopardize their termination payments by either

trying to sell or compete against State Farm. It's just not logical.

Fuqua's assertion that if the agency is sold or assigned for a profit

termination payments are forfeited is unfounded, not grounded in

anything and not logical. There is no evidence that says that if an agent

sells his book of business, with State Farm permission, to obviously an

approved agent he/she loses his termination payments. What is not

logical here is for State Farm to give permission for an agent to sell

their business to Allstate or another insurance company's agent, thereby

competing with State Farm. Termination payments are not affected by

selling an agency to another State Farm agent with State Farm

permission as the seller/agent is not competing with State Farm. As

Fuqua states, "Like I said, because of the termination payments, being

so lucrative, no one would want to jeopardize their termination

25
payments by either trying to sell or compete against State Farm. It's just

not logical." It is definitely not logical for an agent to not seek State

Farm permission to sell the agency to another State Farm agent and it

would not be logical to retire before receiving full retirement benefits.

e. Fuqua's admission that insurance agencies are sold and valued by

similar comparables and that he did such in this case. {TRV2 P. 188,

lines 4-8)

f. No State Farm expert testimony was in evidence, as Court admits,6

other than documents straight from State Farm.

g. Fuqua admitted he is not a State Farm expert or representative, nor has

he ever worked for State Farm {TRV2 p. 172, lines 4-7p. 174, lines 14-

16) and only knows about State Farm through Petitioner and the agent's

agreement. (TRV2 P. 172, lines 8-15)

h. Petitioner admits his father transferred accounts to him when he got

started. (TRV2 P. 91, lines 18-23)

1. Petitioner admits his contract states agency can be sold with State Farm

permission. (TRV2 p. 94, lines 15-19)

6 TRV3 P. 107 "The Court: Unless you-all brought an expert in from State Farm, which you did

not ..... ";

26
j. Fuqua, thirty-year accountant, clearly valued DHIA. (TRV2 p. 193, line

8-9; EX F)

k. Petitioner's admission that no State Farm expert is there to validate his

testimony that contradicts the DHIA/State Farm contract. (TRV2 P. 94,

lines 23-25, P. 95, Line 1)

I. Petitioner's admission, that he himself, hired Fuqua to value DHIA.

(TRV2 P. 95, lines 4-6)

Without FFCL, it appears the Court used the excuse to completely divest

Respondent of her interest in DHIA on insufficient evidence and grounds, relying on

contradictory verbiage from a non State Farm expert, that "the business cannot be

sold" (TRV2 P. 199, lines 1-3), while also admitting it can be sold with State Farm

permission, and all while ignoring the actual State Farm evidence stating in black

and white that it can be sold with permission and the admissions thereto. No

reasonable, fair minded person would disregard the State Fann/DHIA contract and

admissions, and award the wife zero for the value of the business, nor at a minimum

equalize Respondent's share elsewhere in the estate. This is legally and factually

insufficient evidence, clear error, an abuse of discretion, manifestly unjust and so

unfair to just be plain wrong. Even if the business could not be sold, a divisible value

still exists, which is why a value was placed, and a reasonable and objective fair

minded person would divide it. Should DHIA not be able to be sold and/or had no

27
value to divide upon divorce, either way, Petitioner would not have spent $ 8,000

valuing the business and would have hired a State Farm expert to come state that the

business cannot be sold or assigned through any manner. Petitioner, himself,

received assigned accounts in the past. Of note, the termination payments are not

payments made for the sale of the business either.7 Those benefits are separate and

apart from the sale of the business.

In Hancock, the spouse owned an insurance agency with no buyers, derived

during the marriage, and the Court considered this agency to be a community

business t~at consisted of an insurance agency receiving income from renewal of

premiums that arose during the marriage. Hancock v. Hancock, No. 2-06-376-CV

(Tex. App. 7/31/2007, No. 2-06-376-CV {Tex. App. Jul 31, 2008) "Because the

business was the community asset being valued, not the individual renewals, we

cannot say that Rice improperly considered the anticipated revenue in valuing the

agency or that the trial court abused its discretion by including the amount in its

valuation of the agency." Id at *7 "Based on the above discussion, we hold that the

trial court did not abuse its discretion by valuing the insurance agency at $

170,520.00." Id. Similar to Hancock, DHIA had a value placed, $ 728,000, after

7
"While Baker built the insurance agency; the tools he used were on loan from State Farm. State
Farm's termination payments were not for the sale of a business where a buyer was able to step
into the seller's shoes." Warren Baker, JR and Dorris J. Baker vs. Commissioner of Internal
Revenue, No. 02-3262 US Court of Appeals (2003) Termination Payments are ordinary income."
Id at 5.

28
considering all factors and the Court should have divided the value the same as in

Hancock. Regardless of whether there was a buyer, whether or not it could be sold,

the law requires a fair, just and right division of a marital .estate and to arrive at such

the Court should have awarded$ 364,000, to be paid to Respondent over time, or

have equalized the division of the estate by awarding Respondent her share ofDHIA,

$ 364,000, in another manner such as all of 107 Nesmith.

C. UNEQUAL DIVISION OF THE MARTIAL ESTATE CAN EASILY
BE REMEDIED
The disparagingly disproportionate and unfair overall division of the

community estate can be remedied by this Honorable Court by ordering the trial

court to award Respondent her$ 364,000, interest in DHIA, to be paid over a period

of time. This is not to include retirement benefits or spousal maintenance. Awarding

Respondent her share of the $ 364,000, to be paid over time, would better equalize

the estate to a 51/49% division of the marital estate, though Petitioner will continue

to make substantial income for years to come based on the renewal of premiums

derived during the 23 year marriage. This would also allow Respondent to have an

income to qualify to assume the mortgage on Elsby and afford her an opportunity to

rehabilitate herself in the workforce while not becoming indigent in the process, as

she is fifty-five years of age and ill. (TRV3 P. 50, lines 11-P. 51, line 12) Retirement

is built over decades, not over ten years. By the time Respondent is sixty years of

age, she would have used all of the retirement fund awarded to her to meet her

29
minimum reasonable needs since that is how she is supporting herself now while

trying to build a real estate and mortgage company, after being denied countless jobs.

(SRSM P. 47, lines 12-21, P. 29, lines 7- P. 30, line 8) Being awarded one half of the

real property was just but it takes time to sell real property and in the meantime

property taxes, mortgage, living and upkeep must be paid. Divesting Respondent of

$ 364,000, that rightfully belongs to her, when an estate could support awarding such

to the wife, is an abuse of discretion as that lack of division is manifestly unjust and

unfair. Our legislatures and Courts created the standard, just, right and fair division

of a marital estate to protect both parties in a divorce.

Furthermore, Petitioner rendered the estate cash poor so there was not much

liquid money to divide for the wife to live on. (EX A) The money that could be

borrowed against, without having to qualify, were the whole life policies which were

given to Petitioner completely. This left Respondent without a way to access any

money since she does not currently qualify for loans. Now that the community

business was given to the Petitioner, without a buyout, Petitioner earns about $

35,000 to $ 40,000 per month while Respondent earns $ 0.00 per month. This must

be equalized. In fact, Respondent is paying for leads, with her retirement money she

is pulling out, to try to obtain real estate and mortgage clients but has received zero

income to date. (See Spousal Maintenance section of the brief) Petitioner filed for

divorce, not Respondent, and had Respondent still been married she would also be

30
earning $35,000 to $40,000 per month and would not be in financial distress. Given

the factors in Muri, if an unequal division of the estate were to occur, it would have

been reasonable for Respondent to receive a higher percentage of the estate due to

her lack of income, age, years of marriage, health and the nature of the property.

Respondent prays this Honorable Court reverse the trial Court and award

Respondent$ 364,000, for her share ofDHIA, to be paid over time.

II.THE TRIAL COURT ERRED, MISAPPLIED THE LAW AND
ABUSED HER DISCRETION IN REDUCING THE VALUE OF
RESPONDENT'S EXTENDED TERMINTION PAYMENTS (RETIREMENT
BENEFITS) WHEN A CLEAR VALUE EXISTED AT THE TIME OF
DIVORCE

The Court erroneously reduced the value of Respondent's extended

termination pay from 31.63% of$ 6,816.00 to 31.63% of$ 4,269.00 based on

insufficient evidence, not understanding what "actuarial" means, a misapplication of

and contrary to law. (TRV3 P. 106, line 24- P. 110, lines 9; EX B & C; CR P. 84-114

& TRV3 P. 816) There is no "actuarial division" at State Farm, as stated by the

Court, (TRV3 P. 109, lines 13-14) evidencing that she did not understand what her

ruling actually was. The Court refused to view Exhibit B (TRV3 P. 106, lines 11-

12), which Respondent was utilizing to seek clarification on whether the 31.63%

would apply against the $ 6,701 or the actuarily reduced amount of$ 4,169.00,

values assessed as of May 30, 2024. The document, EX B, clearly shows the

numbers earned, as of May 30, 2024, and below a different set of numbers if one

31
retires early. It would not be logical, as stated by Fuqua, to risk losing full retirement

benefits. Consequently, Petitioner, if he didn't qualify under the Early Notification

Program to retire on June 20, 2024, for full benefits, would not likely retire before

the age of sixty-five (65) since he was a few months shy of sixty (60) years of age

upon divorce. With that said, Petitioner already qualified for full benefits under the

Early Notification Program. The Court would not allow Respondent to place the

document so that clarification could be obtained. (TRV3 P. 105, line 23 - P. 106,

lines 23) However, the Court allowed Petitioner to argue facts so she could comply

with their analysis to award the actuarily reduced value of extended termination

payments, instead of the already earned amount, that she herself did not understand.

State Farm, themselves, had already determined the value of benefits earned as of

June 20, 2024, the date of divorce, in black and white, and the Court ignored that.

(EX B) State Farm's evidence weighs much more than an accountant who has never

worked for State Farm, nor is a State Farm expert. Clearly, the Court erred by not

understanding what actuarially reduced is, by ignoring State Farm's clear

numbers/values as of the date of divorce and not applying the correct value to

Respondent's 31.63% of the extended termination payments (EX B; TRV3 P. 6-8),

regardless ofFuqua's non State Farm expert testimony, and in compliance with Berry

and Wade.

32
Extended termination payments are characterized as community property

and should be divided upon divorce.8 The court properly characterized the

extended termination pay as community property. {TRV3 P. 88, line 22) The

Court properly determined the percentage of 31.63% of the retirement benefits,

based on the years of marriage. However, the court committed error when she

reduced the value of these retirement benefits without following Berry, Wade and

other case law, and without an understanding of what "actuarily reduced" is as

she thought that was a division of State Farm. When the value of such benefits is

in issue, however, the benefits are to be apportioned to the spouse based upon the

value of the community's interest at the time of divorce. Matter of Marriage of

Wade, 923 S.W.2d 735 at *739 (1996); Berry v. Berry, 647 S.W.2d 945, 947

(Tex.1983) "Specifically, the trial court is to determine the amount of benefits the

earning spouse would receive on the date of divorce IF he or she WERE

ELIGIBLE for the benefits on that date. Id at 946. Though Petitioner, as of May

30, 2024, qualified for the $ 6,701, and as of June 20, 2024, qualified for the $

6,816, value of extended termination payments under the Early Termination

Program (EX B), Respondent argues, in the alternative, under Berry and Wade,

8
"Unmatured retirement benefits earned during marriage are community assets subject to
division upon divorce; such benefits are not earned on day on which they mature, but are instead
a form of deferred compensation earned each month of employment; at time of divorce, they
constitute contingent property interest of the marital estate." In the Matter of the Marriage of
William C. Wade and Frances Carol Wade, 923 S.W.2d 735 (Tex.App.-Texarkana, 1996, no
writ);

33
this deferred compensation is valued as if ELIGIBLE TO RETIRE, regardless.

The $ 6,701 value was undisputedly earned as of May 30, 2024, according to State

Farm. (EX B) Because Petitioner was not sixty-five (65), at the time of divorce,

does not negate the value earned as of the date of divorce, June 20, 2024, which

was $ 6,816. (EX B) If Petitioner did not qualify under the Early Notification

Program, which he did, then IF he were fully eligible to retire on the date of

divorce the value of extended termination payments was$ 6,816.00, as per State

Farm, the ONLY State Farm evidence. By the time Petitioner retires, that amount

will increase. Respondent is not entitled to the increase over$ 6,816.00, and did

not request for any amount above$ 6,816.00.

Our legislatures would never devise a system where retirement benefits are

earned during a marriage, but upon divorce, the nonworking spouse doesn't

acquire the already earned retirement benefits just because the working spouse is

not eligible to RECEIVE them at the time of divorce. That would be unjust leaving

a working spouse with all of the retirement and the nonworking spouse, who likely

cared for the kids and for the working spouse, for years, without a retirement at

all. Many companies do not provide retirement benefits at all if one retires before

the designated age of retirement with that company. All of those nonworking

spouses, or stay at home spouses, would not have any retirement income under

34
that scenario. Our legislature protects nonworking spouses and stay at home

moms and dads from this very abuse.

In Berry, Berry, at the time of divorce, was NOT entitled to ANY

retirement benefits at all because he was not yet sixty years of age, which was the

prerequisite under the noncontributory retirement plan. Berry, 641 S.W.2d 945

(Tex.1983) However, though Berry was making $ 946.34 per month, at actual

retirement, Berry would have received $ 221.21 per month had he been fully

eligible to retire at the time of divorce. Id. at 946. Berry had already earned $

221.21 per month for retirement at the time of divorce but could not receive it

until he was 60 years of age. Similarly, Petitioner had already earned $ 6,816.00,

per month, but was not yet eligible to receive it, since he was not yet 65 years of

age, that is ifhe did not qualify already under the Early Notification Program.

Though Ms. Berry was not entitled to any post divorce increases m

retirement benefits, she was entitled to$ 110.60 per month, 50% of what the value

was at the time of divorce AS IF ELIGIBLE to retire. Id Similarly, Respondent

is entitled to receive 31.63% (based on years of marriage) of$ 6,816, as of the

date of divorce, as if Petitioner was 65 years of age and fully eligible to retire on

the date of divorce. Again, Petitioner was actually already eligible under the Early

Notification Program as well. (EX B)

35
Reducing the value of Respondent's extended termination payments was clear

error, unjust, unfair, misapplication of law, misunderstanding of the facts and law, a

misunderstanding of what actuarily reduced means and how that does or does not

apply, and an abuse of discretion. Logically, Petitioner would have hired a State

Farm expert to testify had the value been$ 4,269.00, at the time of divorce. In reality,

had a State Farm expert testified, that expert would have reiterated the document

produced by State Farm that the earned value is $ 6,816.00, at the time of divorce.

Respondent requests this Honorable Court order the trial Court to award

Respondent 31.63% of$ 6,816.00, the value at the time of divorce, to be paid for

Extended Termination payments if, as and when received by Petitioner.

III.
THE TRIAL COURT ERRED AND ABUSED HER DISCRETION
IN DENYING SPOUSAL MAINTENANCE

Under Tex. Fam. Code Sec. 8.051, 8.052, 8.053, and 8.054, the court may

order maintenance for either spouse only if the spouse seeking maintenance will lack

sufficient property, including the spouse's separate property, on dissolution of the

marriage to provide for the spouse's minimum reasonable needs if the spouse has

been married to the other spouse for 10 years or longer and lacks the ability to earn

sufficient income to provide for the spouse's minimum reasonable needs and has

exercised reasonable diligence in earning sufficient income to provide for her

36
mm1mum reasonable needs or developing skills necessary to provide for her

minimum reasonable needs.

Here, though there is much real property, the nonworking spouse, wife and

mother, does not have any income, nor liquid assets, nor does she have any access

to borrowing money. In fact, Respondent was left without sufficient money to pay

for her own counsel. As such, Respondent's first attorneys were not fully defending

Respondent and minimizing the required discovery disclosures. (SCR P. 7, 11) Said

counsel withdrew from representing Respondent. (SCR P. 13) Respondent's sister

filed a notice of appearance and represented Respondent free of charge (SCR P. 17)

because Respondent had been left without money. Moreover, Respondent had to file

a Motion for Temporary Orders because Petitioner had closed bank accounts and

credit cards preventing Respondent from accessing any money to live and pay bills

while one child was still under 18 years of age. (SCR P. 20 - 22) Petitioner spent

roughly$ 109,000, in one attorneys' fees (TRV3 P. 76, line 3), and unnecessarily

brought in another attorney from San Antonio, Orsinger, as well, and spent more

money on attorneys' fees. Petitioner benefited greatly from Respondent's sister not

having charged the estate to defend Respondent the same $ 109,000 + Orsinger's

fees, Petitioner's attorneys gained. The time Respondent and her attorney spent to

attempt to figure out the finances was enormous since Petitioner controlled all of the

finances. With that said, attorneys were not necessary at all for Petitioner since

37
Respondent's sister offered to draft the decree for free provided all would be split

50/50. (TRV3 P. 146, lines 4 - 12)

Furthermore, had the Court awarded Respondent some of the whole life

policies, she could have at least borrowed against them, without having to qualify

for a loan, to help pay for her share of the real property taxes and upkeep and to

otherwise survive. See as follows:

SRSMP. 39, lines 16-23 (Maribel Hill Testimony)

Q. (By Ms. Lopez) Do you currently have financial stability?

A.No.

Q. The whole life policies, would they have provided you a way to have
income?

A. Yes.

Q. Do you qualify for a loan currently?

A.No.

The marital estate paid on the while life policies for 23 years and the policies

were in debt at the time of marriage. (TRV3 P. 49, lines 6 - P. 50, line 10)

Respondent qualifies for spousal maintenance. (SRSM; SCR P. 225-244 & P.

448-523) She was a stay-at-home wife and mother for twenty-three years (TRV3 P.

70, lines 24-25, P. 71, lines 1-7, P. 72, lines 14-15) and now lacks the ability and

health to earn sufficient income to provide for her minimum reasonable needs.

38
(TRV3, P. 31- P. 32, line 14, P. 10, lines 12-16, P. 51, lines 11-16, P. 52, line 25, P.

53 - P. 54, line 17; SME entire transcript, SME P. 9 line, 16 - P. 11, P. 14, lines 6-

25, P. 15 lines 1-25, P. 16, lines 1-21, P. 23, lines 23-25, P. 23, lines 1-3, P. 37, lines

4-20, 24, P. 38 line 1-24; SRSM entire transcript) Respondent, though credentialed,

lost earning capacity by being at home tending to her husband and kids instead of

building her career. While separated and thereafter, Respondent took classes to learn

the new market in real estate, study and retake her exams for her mortgage license

and applied for countless jobs of which she was repeatedly denied employment.

(SCRp. 225-244, 448-523; SRSMtranscript) Respondent, age 55, could only obtain

100% commission jobs in the real estate and mortgage market and sadly has not had

one closing. (SCR p 225-244, 448-523; SRSMtranscript) Respondent had to file for

temporary spousal maintenance pending appeal, and after three settings (SCR P. 1-

4), of which Respondent was turned away from at the Courtroom, on the third try

the motion was finally heard but never ruled on. (CR P. 12) The evidence at trial

showed Respondent did not earn money in any business venture during the marriage.

(TRV3 P. 30 - P. 31, line 15) The estate was kept cash poor (EX A) All whole life

policies that could be borrowed against were given to the husband. (TRV3 P. 95,

lines 21-24) Real property exists that has not sold and costs money to maintain and

a wife/mother, like all human beings, have financial needs to survive. Currently,

Respondent is paying penalties and taxes on the money she is having to pull out to

39
survive from her retirement account. Respondent has applied for countless jobs but

no one will employ her. See as follows:

SRSM P. 37, lines 4-21 (Maribel Hill Testimony)

Q. Why are you asking the Court of Appeals to find you indigent for purposes
of appeal?

A. Because I do not have an income, and I have been looking for a job, and I
was not awarded any spousal maintenance nor was I awarded half of the
business that was created after marriage.

Q. Do you have an income?

A. No.

Q. Do you have access to cash money?

A. I have investments that when I pull out, I have to pay penalty and taxes on.

Q. Is that how you're living today?

A. Yes.

Q. How did you pay property taxes?

A. Pulling out money from my retirement.

Q. And, at this point, when will that retirement be exhausted?

A. Within three years.

SRSMP. 38, lines 11- 24 (Maribel Hill Testimony)

Q. Have you done everything that you can to find a job?

A. Yes.

40
Q. Are you trying to rehabilitate yourself in the workforce?

A. Yes.

Q. Did you take classes to rehabilitate yourself in the workforce?

A. Yes, real estate and mortgage classes.

Q. And who was the primary caregiver of the kids?

A.Me.

Q. And do these kids still come home to stay with you?

A. They live with me.

Respondent deserves the opportunity to transition into independent living

without becoming indigent in the process. Justice is severely compromised when

one spouse is allowed to remain with the entire community property business and

earn$ 35,000 to$ 40,000 per month, while the stay at home mom and wife of 23

years becomes indigent and can't support her reasonable needs because she is no

longer marketable in the workforce. The nature of the property divided was mainly

real property that requires an income to maintain and not lose in a foreclosure. As

already stated, the only liquid money was in the whole life policies and in the income

generated by DHIA. A reasonable and fair minded person would never leave a

nonworking spouse without access to liquid money or award an entire community

business to one spouse. This is an injustice, unreasonable and just plain wrong. Our

legislatures devised Tex. Fam. Code Sec. 8.051, 8.052, 8.053, and 8.054, to help the

41
class of people just like Respondent from becoming indigent as a result of staying at

home to care for the family, instead of building their careers, and then finding

themselves divorced and indigent. Respondent is the very person our legislatures

created these statutes to protect. Respondent qualifies and has complied with all of

the necessary requirements and deserves the protections afforded her under Tex.

Fam. Code Sec. 8.051, 8.052, 8.053, and 8.054. Spousal maintenance should have

been awarded for at least five years.

Respondent prays that this Honorable Court will order the trial Court to award

Respondent$ 5,000.00, per month, as spousal maintenance for five years, which is

only half of what Respondent needs to meet her minimum reasonable needs to

survive and to maintain her real property while she rehabilitates herself in the

workforce.

IV. FOLLOWING A BENCH TRIAL, RESPONDENT TIMELY FILED
HER FINDINGS OF FACT AND CONCLUSIONS OF LAW AND HER
NOTICE OF PAST DUE FINDINGS OF FACT AND CONCLUSIONS OF
LAW. DESPITE AN OBLIGATION TO DO SO, THE TRIAL COURT NEVER
MADE FINDINGS OF FACT AND CONCLUSIONS OF LAW.

What was the basis for why the Court awarded the entire community property

business to the husband without an equalization of the value of the business to wife?

What was the basis for why the Court reduced the already earned value of the

extended termination payments to the wife, especially since she thought State Farm·

42
had an "actuarial division"? What was the basis for not awarding ANY spousal

maintenance and ignoring that our legislatures allow up to seven years of spousal

maintenance, Sec. 8.054 (l)(B), to a stay at home wife and mom of twenty-three

(23) years to give her an opportunity to rehabilitate herself in the workforce and not

become homeless at the age of sixty (60)? What was the basis, after hearing that the

wife had not been able to gain employment and had zero income or way to access

money, because the Court depleted her of that, other than to drain her retirement

account, for not awarding any spousal maintenance, even pending appeal?

Findings of fact and conclusions of law would certainly help answer these

questions. Respondent timely filed her request for findings of fact and conclusions

of law. (CR P. 113-118) Respondent timely filed her past due notice for findings of

fact and conclusions of law. (CR P. 164-166) The Court requested Petitioner's

attorney draft her findings of fact and conclusions of law (TRV3 P. 110, lines 1-9)

to which Respondent objected to. (CR P. 186-189) That practice only gives

opposing counsel an opportunity to state what he/she wants a court to determine

and defeats the purpose of receiving FFCL from the Court. Such a practice should

never be allowed in our court system. Nevertheless, the court failed to make her

findings of fact and conclusions of law.

When a trial court has served as the fact finder, the trial court is required to

make findings of fact and conclusions of law following a timely request. Cherne

43
Indus., Inc. V.Magallanes, 163 S.W.2d 768, 772 (Tex. 1989) ("the trial court's duty

to file findings and conclusions is mandatory"); Landerman v. State Bar of Texas,

247 S.W.3d 426, 430 (Tex. App. - Dallas 2008, pet denied) ("When properly

requested, the trial court has a mandatory duty to file findings of fact."); see also

Tex. R. Civ. P. 297 ("The court shall file its findings of fact and conclusions of

law.") Moreover, a trial court's failure to make findings of fact and conclusions of

law is generally presumed harmful. Tenery v. Tenery, 932 S.W. 2d 29, 30 (Tex.

1996); Cherne Indus., Inc. v. Magallanes, 163 S.W.2d 768, 772 (Tex. 1989). The

court should have made findings of fact and conclusions of law and given

Respondent the opportunity to understand how the awards, and lack thereof, raised

in this appeal complied with the laws that Texas has to ensure that a just, right and

fair division of a marital estate ensues while protecting the rights and well-being of

BOTH parties, not just one. This also would have afforded Respondent the

opportunity to request additional findings of fact to clarify any remaining questions.

Tex. R. Civ. P. 298.

V. PRAYER

Respondent prays this Honorable Court will reverse the trial court's judgment

and equalize the division of the community estate by rendering judgment that

Respondent is entitled to $ 364,000, her share of the value of DHIA, to be paid

monthly over the course of three years, render judgment that the value of the

44
extended termination pay be that of$ 6,816.00 to be paid at 31.63% to the wife, as,

if and when received by Petitioner and render judgment that Petitioner is to pay

Respondent$ 5,000 per month for five years in spousal maintenance. Respondent

further prays that this Honorable Court will reverse the trial's court's order requiring

Respondent to sign a Deed of Trust to Secure Assumption, on behalf of Petitioner,

for Respondent's separate property. Alternatively, Respondent prays that this Court

reverse and remand with instructions that the trial court make findings of fact and

conclusions of law, herself, and not allow Petitioner's attorneys to draft such for her.

Respondent also prays for her costs and for all other relief to which she may be

entitled.

Respectfully submitted,

Isl Marisol Lopez
MARISOL LOPEZ LAW FIRM
Marisol Lopez
State Bar No 24050952
301 W Avenue D
Garland, TX 75040
972-205-1110 office
1-866-232-2077 facsimile
marisol@lawyerforu.com

CERTIFICATE OF COMPLIANCE
I certify that, according to my word processor's word-count function, in the
sections of this brief covered by TRAP 9.4(i)(l), there are 10,892 words.

45
Isl Marisol Lopez
Marisol Lopez

CERTIFICATEOF SERVICE

Counsel for Movant/Appellant certifies that a true copy of this Notice has been
forwarded in accordance with TRAP 9.5 this _21st_ day of August, 2025 to

Petitioner Dwight Hill's lead attorney:
EPSTEIN FAMILY LAW, P.C.
Robert D. Epstein
State Bar No. 24065206
robert@epsteinpc.com
5949 Sherry Lane, Suite 1070
Dallas, TX 75225
Tel: (972) 232-7673

And

ORSINGER, NELSON, DOWNING & ANDERSON, LLP
Richard R. Orsinger
State Bar NO. 15322500
425 Soledad, Suite 550
San Antonio, Texas 78205
210-225-5567
richard({.~ondafamilylaw.com

Attorneys for Petitioner/ Appellee

Isl Marisol Lopez
Marisol Lopez
Attorney for Maribel Hill,
Respondent/ Appellant

46
APPENDIX
EXHIBIT A

WIFE'S AMENDED
PROPERTY DIVISION
In the Matter of the Marriage of Hill

Wife's Husband's
Value Used Percent to
Note Description Proposed Proposed To Husband To Wife Percent to Wife
for Division Husband
Value Value
COMMUNITY ASSETS

REAL PROPERTY (including Mineral Interests)
1 1211 Ft Velasco Surfside Beach TX 77541 $265 000 $350,000 $265,000 0% 100%
2 123 Nesmith Pl, Surfside Beach, TX 77541 (agreed) $75,000 $75,000 $75,000 100% 0%
107 Nesmith Pl, Sufs1deBeach, TX 77541 (Lots 1, 2 &
3) Lot 3 is currently for sale but price needs to be
3 S546.000 5546,000 $273,000 $273,000 50% 50%
lowered (Propose Lot 1 for W, Lot 2 for H and Lot 3
soldl
4 118 Nesmith Pl, Surfside Beach, TX 77541 (Agreed) $75,000 $75,000 $75,000 0% 100%

CASH AND ACCOUNTS WITH FINANCIAL INSTITUTIONS
(Including Brokerage and Mutual Funds)
5 Cash on Hand (H\ $10,000 $10,000 100% 0%
PNC Bank Checking account ending 6118 (H&W) alo
6 $126 $126 100% 0%
6/10/24 f aareedl
PNC Bank DLH Separate Savings accountending 2065
7 $27 $27 100% 0%
'Hl a/o 5115/24 faoreed)
State Farm FCU Reglar Shara Account/ Dwight Hill
8 ending 8951/member ID Savings account ending 2289 $204 $102 $102 50% 50%
S1 (H&W) a/o 5115/21\(anreed\
PNC Sank Personal Checking account ending 4643
9 $8,533 $4,267 $4,267 50% 50%
IHS,W) alo 6/10/24 faareed\
PNC Bank Ava Education Account Checking account
10 endlng 2033 (Ava, H&W) a/o 6/10/24 used as a way $2,097 for Ava for Ava for Ava
to transfer monev to Ava {aareed)
PNC Bank Checking account ending 2183 (H) a/o
11 $14,327 $14,327 100% 0%
5/15124laareedl
State Farm Funds Brokerage Joint Tenants account
12 $17,978 $8,989 $8,989 50% 50%
endin □ 5608 IH&W\ a/o 6/10/24 (aareed\
JP Morgan Chase Bank Chase Checking ending 2507
13 Closed Closed Closed
IH&Wl a/o 4/10123 iaccount closed)
JP Morgan Chase Bank Chase Total Checking
account end,ng 2380 (W) a/o 5/8124, W transferred
- --
14 $52,742 $52,742 $52,742 0% 100%
from Chase ending in 2507 (Agreed separate acct); H
had an acct also receivina same amount

Page 1 of 8
In the Matter of the Marriage of Hilt

Wife's Husband's
Value Used Percent to
Note Description Proposed Proposed To Husband To Wife Percent to Wife
for Division Husband
Value Value
CLOSELY HELD BUSINESS INTERESTS
Restore Entertainment, LLC OBA Mousika
15 X X 0% 100%
PubllshlnQ
Chase Bank Complete Business Checking account
a $544 $544 0% 100%
ending in 6763 CW)a/o 518/24 (agreed)
Investment into Restore Entertainment from
b $0 $80,000 $0 0% 100%
communitv (both were investors & both lost monevl
Dwight HIii Insurance Agency, Inc. (appraisal not
16 updated with higher numbers though Income > $728,000 $0 $400,000 $400,000 50% 50%
hit1herl
PNC Bank Business Checking account ending in 3338
a (H&W) a/o 05/15/24 (Agreed leave $ 3k and split $2,441 X 50% 50%
remainder)
2022 Toyota 4Runner (in possession of Ava) a/o
b $43,000 0% 0%%
05/31/24; (Agreed title to Ava Hill}
17 Grateful Hlooies LLC (Agreed assign to wife\ $0 X 0% 100%
PNC Bank Business Checking account ending in 4123
a $117 $117 0% 100%
(H&Wl a/o 5/15/24 (Aareedl
RETIREMENT ACCOUNTS AND OTHER DEFERRED
COMPENSATION (Including Union Benefits) 50150 as of
State Farm Fund Maribel Hill Roth IRA ending in 9212
18 $34,521 $30,500 $17,261 $17,261 50% 50%
CW)a/o 6/10/24
State Farm Fund Dwight Hill Roth IRA ending in 9211
19 $33,815 $16,908 $16,90B 50% 50%
IHI a/o 5/15/24
State Farm Pershing 4620 ROTH IRA formerly Slate
Farm BlackRock A6KTA (current account balance as
20 $615,382 $307,691 $307,691 50% 50%
of 5/8/24); Dwight's account; account is of mixed
character
State Farm Pershing 9931 ROTH IRA forrnery State
Farm BlackRock A6KTA (current account balance as
21 S155,547 $77,714 $77,774 50% 50%
of 5/15124); Dwight's account; account is of mixed
character
Ascensus Trust IRA Services account ending in 2370
~
-
22 (also known as State Farm Brokerage Investment $63,078 $31,539 $31,539 50% 50%
6955 - subaccount\ CH\a/o 518/24
Ascensus Trust IRA Services account ending in 2370
23 (also known as State Farm Brokerage Investment $50,650 $49,752 $25,325 $25,325 50% 50%
6956 - subaccount) CW)a/o 617/24
State Farm Black.rcx;kMaribel L Hill ending in C17dn
24 $111,051 $109,964 $55,521.l $55,526 50% 50%
l(WI same as 4612 '8/o 6/"10/24 __ ..,__
-
Page 2 of 8
In the Matter of the Marriage of Hill

Wife's Husband's
Value Used Percent to
Note Description Proposed Proposed To Husband To Wife Percent to Wife
for Division Husband

25
State Farm Blackrock Maribel L Hill ROTH IRA ending
Value
$146,435
Value
$143,926
--
$73,218 $73,218 50%
in C9ASY same as 9964 a/o 6/10/24 50%

OTHER DEFERRED COMPENSATION BENEFITS

Termination Payments for H employment through SF
paid out monthly after H retires; 66% to Husband and
34 % to wife = $2,710.40 first 5 years and then$
26 66% 34%
2,680.40 after 5 years forward); H gets$ 4,472.16 first
5 years and $ 2,680.40 after first 5 years; H will
actually get more by teh time he retires

MOTOR VEHICLES, BOATS, AIRPLANES, CYCLES, ETC.

Honda Scooter Elite (Name on title: H); at 4647 Elsby;
27 $600 $600 $600 100% 0%
W claims her name 1son title
2014 Club Car Gas xtr 850 (Name on title: H); at 1211
28 $2,500 $5,000
Surfside Beach (qoes w whoever has Velasco)
2010 Lexus LX570 (Name on ti1le·H&W); in
29 $22,000 $20,000 $20,000 100% 0%
possession of H (No lien) ( Aareed)
2021 Mazda CX-5 (Name on title. W); in possession of
30 $24,000 $25,000 $25,000 0% 100%
Wile { Aoreed}
2022 Ford F-150 (Name on title: H&W): in p~essian
of Jacob ($45,000 FMV less $2,157 owed a/o
31 $48,000
10/25/23; paid off a/o 3/12/24) Vehicle to be titled to
Jacob Hill. Mneed
MISCELLANEOUS ASSETS
32 Clothes, bicvcle, books, guitar tools (poss Hl $5,000 $5000 100% 0%
Household f1.Jrn1sh1ngs,musical insirumen'\s & tools
33 $5,000 58,000 $5,000 0% 100%
(Aoreed)
34 Comouter monitors lx2l (poss· Hl (Aoreedl $100 SlOO 100% 0%
35 Glock 26 (ooss. Hl (Aort1ed) $500 $5QQ_ 100% 0%
36 Sig P23S (ooss: W) (Aaraadl $450 $600 $450 0% 100%
4.53 ct Diamond/Platinum Ring (poss: W) (can nsure
no
37 jewlrey w no appraisal but not even Insured for that $75,000 0% 100%
appraisal/gift
amount): olft to W
Diamond necklace (poss. W), (can insure for whatever no
38 $15,000 0% 100%
but not even insured for that): Gift to W aooraisaVoift
39 Maribel Hill Music (Agreed) $0 unknown $0 0% 100%

Page 3 of 8
In the Matter of the Marriage of Hill

Wife's Husband's
Note Value Used Percent to
Description Proposed Proposed To Husband To Wife Percent to Wife
for Division Husband
Value Value
Unknown jewelry and papers in PNC Bank Safe-
40 TSO 0% 100%
Deposit Box (Aqreed)
INSURANCE

State Farm ending in 2752 Whole (H); $250K face
41 value (Wis beneficiary); date of issue is 09/25/1989; $94,997 $ - $94,997 0% 100%
acct in debt of 16,819.20 as of 10/15/2001; a/o 6.4.24
State Farm ending in 5601 Whole (H}; $1OK face value
(Wis beneficiary); date of issue is 08/23/1988;
42 $4,020 $4,020.39 100% 0%
therefore, it is not H's SP a/o 6/4/24 be paid the
oremiurns throuahout marriage
State Farm ending in 2655 Whole (H); $25K face value
(Wis beneficiary); date of issue is 09/25/1989;
43
therefore, it is not H's SP a/o 6/4/24 be paid premiums
$9,709 $ - $9,709 0% 100%
for 23 vears
State Farm ending In 8176 Whole (H); $1 OK face value
44
0N is beneficiary); date of issue is 09/28/1990;
$4,684 $4,683.51 100% 0%
therefore, it is not H's SP a/o 6/4/24 be paid premiums
for 23 vears
State Farm ending in 0889 Whole (Garrett insured,
owner TBD); $50k face value; W 1sbeneficiary:
45 however, date of issue is 05/24/1990; therefore, it 1s $8,369 $ - 0% 0%
not H's SP a/o 6/4/24 be paid premiums for 23 years
/Aoreed utle to Garrett!
State Farm ending in 2774 Whole (H), $250K face
value (W Is beneficiary) date of issue is
46 S90,128 $90,128.00 100% 0%
09/25/1989;acct was In debt of $20,304.47 as of
10/15/01 a/o 6/4/24
47 State Farm ending in 2821 Term (H), $SOOKface value no CSV X 100% 0%
State Farm ending in 3643 Term (Wl: $400K face
48 noCSV X 0% 100%
value
State Farm ending in 0051 Whole (H owner, Ava Hill
49 insured): $SOK face value (W ,s beneficiary) ulo 6/4/24 $2,041 $2,841
-
0% 0%
(Aoreed title ownership to Ava Hill)
State Farm ending in 1479 Whole (H owner: Jacob Hill
50 insured), $SOKface value (Wis beneficiary) a/o 6/4/24 $3,151 $3,318 0% 0%
/Aareed Title ownershio to Jacob HIil)

Page 4 of 8
In the Matter of the Marriage of Hill

Wife's Husband's
Value Used Percent to
Note Description Proposed Proposed To Husband To Wife Percent to Wife
for Division Husband
Value Value
REIMBURSEMENT CLAIMS

H claims reduction of princpal amount of debts
secured by liens on Ws SP residence at 4647 Elsby
Avenue, Dallas, Texas 75209. But no reimbursement
claim exists as the mortgage is 3 times higher than
Howes$
before marriage; and H received benefit & was already
126,000.00 to
51 compensated by acquiring paid off assets with the $378,000 0% 0%
Elsby (half
equity money out of separate property & never paid
mortgage)
back the equity$ he withdrew on the separate
property) Howes$ 126,000 to Elsby or wife needs Ft
Velasco free and clear as equity of Elsby is in that
home while the mortgage remains on Elsby.
H's Separate Property Funds DID NOT invest in capital
improvements to Ws SP residence at 4647 Elsby
52 Avenue, Dallas, TX 75209 from Clubway House. $0 $79,000 $0 0% 0%
Mortgage was placed on it and W had$ 83,000 from
insurance.
There are no community property funds invested in
capital improvements to Ws SP residence at 4647
Elsby Ave, Dallas, Texas 75209 ($83,000 came from
insurance claim premarital & S 100,000 was a loan afer
53 marriage that was never paid back & is part of existing $0
mortgage debt; loan is 3 times higher than before
marriage and H benefited as he is receiving property w
no mortgage be derived from Elsby and Elsby has the
debt $100 000 $0 $0 0%%
Totals $1,516 109 $1,820 158
-- .~%
COMMUNITY llABIUTIES

CREDIT CARDS AND CHARGE ACCOUNTS
Chase Bank, Acct ending 9682 (W) a/o 5/8124
1 ($95) ($95) 0% 100%
Aareedl
2
Chase Bank, Acct ending 7039 (W) a/o 5/8/24
($870)
- -
(Aareedl ($870) 0% 100%

3 CapitalOne, Acct ending 0864 (H) a/o 3/12/24 (Agreed) $0 $0 100% 0%

ATTORNEY'S FEES IN THIS CASE

Page 5 of 8
In the Matter of the Marriage of Hill
I

Wife's Husband's
Note Value Used Percent to
Description Proposed Proposed To Husband To Wife Percent to Wife
for Division Husband
Value Value
4 Eostein Family Law, P.C. (AQreed) accruinQ X 100% 0%
5 Armstrona Divorce and Family Law PLLC (Aoreed) unknown X 0% 0%
6 Marisol Lopez (Agreed) unknown X 0% 100%
OTHER PROFESSIONAL FEES IN THIS CASE
.
7 Steohen Fuqua (AQreed) $0 $0 100% 0%
OTHER LIABILITIES NOT OTHERWISE LISTED
State Farm FCU Line of Credit ending 2289 (a/o
8
3/12/24) (Agreed) $0 $0 100% 0%
Real Property taxes (50/50 paid on taxes up to date of
9 divorce) and split any tax refunds or rebates on tax
returns filed during marriage

Totals ($965) $0 ($965) 0% 100%

SUMMARY OF PROPOSED DIVISION OF COMMUNITY PROPERTY
t-1usband Wife
Grand Total of Assets $0 $1,51& 109 $1,820,158
Less Community Unsecured Liabilities ($965) $0 ($965)
Net Value of Estate ($965) $1516109 $1 819 193
Percentage Division -157183% -188605%
50 Percent of Net Estate ($482) ($482)
Over : (Short) $1 5t6 591 $1,819 675
S 265k Ft. Velasco ror oortfon of Elsbv mortaaae+ $ 52k H alreadt_got)
- _L_ --

Page 6 of 8
In the Matter of the Marriage of Hill

Wife's Husband's
Value Used Percent to
Note Description Proposed Proposed To Husband To Wife Percent to Wife
for Division Husband
HUSBAND'S SEPARATE PROPERTY
Value Value
- -·
No. Descriolion Value of Prooer v
PNC Checking Account 1641 (check issued for 1/4
1 land sale from Bill Hill) a/o 5/15/24 (not separate $9,031.54 $83,598.00
property) $167,195 $83,598 50% 50%
2 $600.00
Levovo Laotop (bouaht with separate property monies) 100% 0%
3 $5,000.00
Gun Cabinet with Gun Collection /aift and purchases) 100% 0%
Gibson J45 Guitar to be given to Jacob Hill (purchased
4 $2,000.00
1997) 0% 0%
5 Life insurance Policies (see above)
6 Reimbursement claim aaainst Elsbv (see above) $0

Total $91198 '

WIFE'S SEPARATEPROPERTY
No. Descriotion Value of Prooert
1 ElsbvSP
4647 Elsby Ave 75209 (FMV=$1,065,000 - Mort
$258,325.320) a/o 10125/2023(W FMV = $758,000) W
to continue to pay loan and Sign hold harmless for H.
Total Separate property that is now 3 times more in debt .
than prior to marriage. H owes half th& mortgage or W
gets Ft Velasco in exchange for his portion of debt in
Elsby. not relevant 100%

CHILDREN'S PROPERTY -
No. Description Value of Prooort,,

1 Blackrock Coverdell, Acct ending 2281 (Ava) (Maribel $38,038.00
Custodian) a/o 5(7/24 £Agreedto title to Ava Hill) 0% 0%
Blackrock Coverdell, Acct ending 4121 (Jacob)
2 (Maribel Custodian) a/o sn/24 \h.graed to litilc to $78,985.32
Jacob Hill) 0% 0%
State Fann Funds Cove1dell,Acct ending 9274 (Jacob)
3 (Maribel Custodian) a/o 6nl24 (Agreed to title to Jacob $9,629.99
Hilll 0% 0%

OTHER REQUESTS:
-

Page 7 of 8
EXHIBITB

STATE FARM TERMINATION
AND EXTENDED
TERMINATION PAYMENTS
VALUED AS OF JUNE 20,
2024, ATTACHED TO
EXHIBIT C (DIVORCE
DECREE)
May 30, 2024

Hill, DwightL
4647 ElsbyAve
Dallas. TX 75209-3203

Dear Dwight,

Following is a review of your estimated Termination and Extended Termination Payments you requested. Section IV,
Paragraph B of the Agent's Agreement reviews the qualifications that must be met in order for Termination Payments to be
made. In order for Termination Payments to be made, the Agent's Agreement must be terminated. The agent will return,
or make available for return, Company property within 10 days of the termination of the agreement. In addition, the agent
agrees to not induce, advise. or solicit any State Farm policyholders in his account at the time of his termination. The agent
also agrees to not act or represent himself in any way as an agent or representative of the Companies. Please see Section
Ill, Termination of Agreement, of the Agent's Agreement for a more thorough review of Termination provisions.

The following are your estimated monthly Termination and Extended Termination Payments by company assuming a
4/30/2024 termination date. Term payments will be made for 60 months following your termination.

Term Pay Ext Term Pay
Auto Voluntary $2,645 $2,645
Auto TCM $19 $0
Fire $198 $193
Lloyds $3,665 $3,636
Fire TCM $125 $125
Health $22 $0
Life $102 $102
Total $6,776 $6,701

NOTE: Extended Termination pay is available to agents who are 60 years or older with 20 years of service (last 10
continuous). Please remember that if you terminate prior to age 65, your Extended Termination Payments will be
actuarially reduced. Extended termination payments are also available for those agents who meet the terms of the Early
Notification Program. Under the Early Notification Program, you can qualify for Extended Termination payments at age 55
if (1) you are at least 55 years old, with 20 years of service (last 10 continuous) OR (2) age plus years of service equals
80.

Extended Termination amounts will be actuarially reduced for retirement before age 65. For retirement at age 59
years 6 months, the actuarial factor of 0.6222 reduces your Extended Termination payments to $4,169 a month. If you
elect the joint and 2/3 survivor option, the extended term amount would be further adjusted to $3,543 a month. The
survivor amount would be $2,362 a month.

NOTE: Life Writing Compensation Payments are based on writing compensation that would have been paid to you if
your Agreement had not been terminated. Life Writing Compensation Payments will fluctuate each month depending
on premium paid each month following termination and payments are reduced by a decreasing commission scale as
business ages and any lapsed/cancelled policies.

NOTE: All figures are estimates. Contract provisions will govern actual amounts.

Attached is the estimate you requested. If you have any additional questions or concerns, please contact an ASR
Representative at 1-833-335-0077 and follow the prompts to contracts and compensation.

Our hours of operation are 7am to 7 pm central time, Monday through Friday.
EXHIB
Sincerely,
Agency/Sales Resources Wa.y
DLH-009152
&State Farm,

June 20, 2024

Hill, DwightL
4647 ElsbyAve
Dallas,TX 75209-3203

Dear Dwight,

Following is a review of your estimated Termination and Extended Termination Payments you requested. Section IV,
Paragraph 8 of the Agent's Agreement reviews the qualifications that must be met in order for Termination Payments to be
made. In order for Termination Payments to be made, the Agent's Agreement must be terminated. The agent will return,
or make available for return, Company property within 10 days of the termination of the agreement. In addition, the agent
agrees to not induce, advise, or solicit any State Farm policyholders in his account at the time of his termination. The agent
also agrees to not act or represent himself in any way as an agent or representative of the Companies. Please see Section
111,
Termination of Agreement, of the Agent's Agreement for a more thorough review of Termination provisions.

The following are your estimated monthly Termination and Extended Termination Payments by company assuming a
5/31/2024 termination date. Term payments will be made for 60 months following your termination.

Term Pay Ext Term Pay
Auto Voluntary $2,640 $2,640
Auto TCM $19 $0
Fire $206 $201
Lloyds $3,763 $3,737
Fire TCM $131 $131
Health $22 $0
Life $107 $107
Total $6,888 $6,816

NOTE: Extended Termination pay is available to agents who are 60 years or older with 20 years of service (last 10
continuous). Please remember that if you terminate prior to age 65, your Extended Termination Payments will be
actuarially reduced. Extended termination payments are also available for those agents who meet the terms of the Early
Notification Program. Under the Early Notification Program, you can qualify for Extended Termination payments at age 55
if (1) you are at least 55 years old, with 20 years of service (last 10 continuous) OR (2) age plus years of service equals
80.

Extended Termination amounts will be actuarially reduced for retirement before age 65. For retirement at age 59
years 7 months, the actuarial factor of 0.6263 reduces your Extended Termination payments to $4,269 a month. If you
elect the joint and 2/3 survivor option, the extended term amount would be further adjusted to $3,625 a month. The
survivor amount would be $2,417 a month.

NOTE: Life Writing Compensation Payments are based on writing compensation that would have been paid to you if
your Agreement had not been terminated. Life Writing Compensation Payments will fluctuate each month depending
on premium paid each month following termination and payments are reduced by a decreasing commission scale as
business ages and any lapsed/cancelled policies.

NOTE: All figures are estimates. Contract provisions will govern actual amounts.

Attached is the estimate you requested. If you have any additional questions or concerns, please contact an ASR
Representative at 1-833-335-0077 and follow the prompts to contracts and compensation.

Our hours of operation are 7am to 7 pm central time, Monday through Friday.

Sincerely,
Agency/Sales Resources

Page 101
EXHIBITC

DIVORCE DECREE
FILED
6/10/20243:31 PM
FELICIAPITRE
DISTRICTCLERK
DALLASCO., TEXAS
John Feltch DEPUTY

NO. DF-22-14398

IN THE MATTER OF § IN THE DISTRICT COURT
THE MARRIAGE OF §
§
DWIGHT L. HILL §
AND § 302ND JUDICIAL DISTRICT
MARIBEL L. HILL §
§
AND IN THE INTEREST OF §
J.L.H., A CHILD § DALLAS COUNTY, TEXAS

COUNTERRESPONDENT'S ANSWER TO FOURTH AMENDED ANSWER AND
COUNTERPETITION FOR DIVORCE

Dwight L. Hill, Counterrespondent, files this Answer to Maribel L. Hill

(Counterpetitioner)'s Fourth Amended Answer and Counterpetition for Divorce.

1. General Denial

Dwight L. Hill enters a general denial.

2. Information about Child

The child the subject of this suit has attained the age of majority and graduated

from high school since the filing of this suit.

3. No Double Recovery

To the extent that Maribel L. Hill seeks to double recover for tort claims alleged in

her Fourth Amended Answer and Counterpetition and her requests for disproportionate

division of the community estate, Dwight L. Hill objects to such double recovery and

asserts that Maribel L. Hill is estopped from such double recovery under the principles

set forth in Schlueter v. Schlueter, 975 S.W.2d 548 (Tex. 1998). An allegedly wronged

spouse has an adequate remedy for alleged fraud on the community through the means

of a just and right division. Therefore, no independent tort cause of action may be

recovered for regarding any alleged damages to the community estate. Id at 585.

Counterrespondent's Answer to Fourth Amended Answer and Counterpetition for Divorce Page 1 of 3

Page 80
4. Attorney's Fees, Expenses, Costs, and Interest

It was necessary for Dwight L. Hill to secure the services of Robert D. Epstein

and Jordan C. Watson of Epstein Family Law, P.C., along with Richard R. Orsinger and

the law firm of Orsinger, Nelson, Downing & Anderson, licensed attorneys, to prepare

and prosecute this suit. To effect an equitable division of the estate of the parties and

as a part of the division, and for services rendered in connection with conservatorship

and support of the child, judgment for attorney's fees, expenses, and costs through trial

and appeal should be granted against Petitioner and in favor of Dwight L. Hill for the use

and benefit of Dwight L. Hill's attorneys and be ordered paid directly to Dwight L. Hill's

attorneys, who may enforce the judgment in the attorneys' own names. Dwight L. Hill

requests postjudgment interest as allowed by law.

5. Prayer

Dwight L. Hill prays that Maribel L. Hill take nothing and that Dwight L. Hill be

granted all relief requested in this Answer.

Dwight L. Hill also prays for attorney's fees, expenses, costs, and interest as

requested above.

Dwight L. Hill prays for general relief.

Counterrespondent's Answer to Fourth Amended Answer and Counterpetition for Divorce Page 2 of 3

Page 81
Respectfully submitted,

EPSTEIN FAMILY LAW, P.C.
5949 Sherry Lane, Suite 1070
Dallas, TX 75225
Tel: (972) 232-7673

By:._--,=-4.a~__.:..___J~'---l-.:,R-£fl-~---
Roliert . Epstein
State Bar No. 24065206
robert@epsteinpc.com
Jordan C. Watson
State Bar No. 24110895
jordan@epsteinpc.com
Attorneys for Dwight L. Hill

Certificate of Service

I certify that a true copy of this Counterrespondent's First Amended Answer was

served in accordance with rule 21a of the Texas Rules of Civil Procedure on the

following on June 10, 2024:

Marisol Lopez by electronic filing manager.

Robert D. Epstein
Attorney for Dwight L. Hill

Counterrespondent'sAnswer to Fourth AmendedAnswer and Counterpetitionfor Divorce Page 3 of 3

Page 82
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.

Jenn Huey on behalf of Robert Epstein
Bar No. 24065206
jenn@epsteinpc.com
Envelope ID: 88633060
Filing Code Description: RESPONSE
Filing Description: COUNTERRESPONDENT'S ANSWER TO FOURTH
AMENDED ANSWER AND COUNTERPETITION FOR DIVORCE
Status as of 6/12/2024 11: 16 AM CST

Associated Case Party: DWIGHTL.HILL

Name BarNumber Email TimestampSubmitted Status
Robert Epstein robert@epsteinpc.com 6/10/20243:31:50 PM SENT

Associated Case Party: MARIBELLEANNHILL

Name BarNumber Email TimestampSubmitted Status

Marisol Lopez Marisol@Lawyerforu.com 6/10/2024 3:31:50 PM SENT

Page 83
ORIG/1~
NOTICE:THIS DOCUMENTCONTAINSSENSITIVEDATA

NO. DF-22-14398

IN THE MATTEROF § IN THE DISTRICTCOURT
THE MARRIAGEOF §
§
DWIGHTL. HILL § 302NDJUDICIALDISTRICT
AND §
MARIBELL. HILL § DALLASCOUNTY,TEXAS

FINALDECREEOF DIVORCE

On June 17, 2024, and June 20, 2024, the Court heard this case.

1. Appearances

Petitioner, Dwight L. Hill, appeared physically in the courtroom. Dwight L. Hill's
attorney of record, Robert D. Epstein, appeared physically in the courtroom and
announced ready.

Respondent, Maribel L. Hill, appeared physically in the courtroom. Maribel L. Hill's
attorney of record, Marisol Lopez, appeared physically in the courtroom and announced
ready.

2. Record

The record of testimony was duly reported by the court reporter for the 302nd
Judicial District Court.

3. ./ Jurisdictionand Domicile

The Court finds that the pleadings of Dwight L. Hill are in due form and contain all
the allegations, information, and prerequisites required by law. The Court, after receiving
evidence, finds that it has jurisdiction of this case and of all the parties and that at least
sixty days have elapsed since the date the suit was filed.

The Court further finds that, at the time this suit was filed, Dwight L. Hill had been
a domiciliary of Texas for the preceding six-month period and a resident of the county in
which this suit was filed for the preceding ninety-day period. All persons entitled to citation
were properly cited.

4. Jury
A jury was waived, and questions of fact and of law were submitted to the Court.

5. Divorce

FinalDecreeof Divorce Page1 of 17

Page 84
The Court finds that Dwight L. Hill and Maribel L. Hill were married on October 191
2001.

IT IS ORDEREDAND DECREEDthat Dwight L. Hill, Petitioner,and Maribel L. Hill,
Respondent,are divorced and that the marriage betweenthem is dissolved on the ground
of insupportability.

6. Child of the Marriage

The Court finds that there is no child of the marriage of Dwight L. Hill and Maribel
L. Hill now under eighteen years of age or otherwise entitled to support and that none is
expected.

7. Divisionof Marital Estate

The Court finds that the following is a just and right division of the parties' marital
estate, having due regard for the rights of each party.

a. Propertyto DwightL. Hill

IT IS ORDERED AND DECREED that Petitioner, Dwight L. Hill, is awarded the
following as his sole and separate property, and Respondent,Maribel L. Hill, is divested
of all right, title, interest, and claim in and to that property:

P-1. The following real property, including but not limited to any escrow funds,
prepaid insurance, utility deposits, keys, house plans, home security access and code,
garage door opener, warranties and service contracts, and title and closing documents:

LOT TWELVE (12), BLOCK TWO (2), SURFSIDE,CONSISTINGOF 0.080
ACRES OF LAND, MORE OR LESS, HEREBY SUBDIVIDED OUT OF
TRACT 212, OUT OF BRAZOS COAST INVESTMENT COMPANY
SUBDIVISION NO. 1, BRANCH T. ARCHER LEAGUE, ABSTRACT 9,
BRAZORIA COUNlY, TEXAS, ANO BEING MORE PARTICULARLY
DESCRIBEDBY METESAND BOUNDS IN VOLUME 1772, PAGE 276 OF
THE DEED RECORDS OF BRAZORIA COUNTY, TEXAS. (ACCOUNT
NUMBER 6751-002-110)

More commonly known as 123 Nesmith Place, Surfside Beach, Texas
77541.

P-2. 35% of the net sales proceeds from the sale of the following real property,
including but not limited to any escrow funds, prepaid insurance, utility deposits, keys,
house plans, home security access and code, garage door opener, warranties and
service contracts, and title and closing documents and more particularlydescribed in the
"Sale of Real Property,.provisions below:

Being Lots 1, 2 and 3 in Block 3 hereby subdivided out of NESMITH Tract
212 in Brazos Coast Investment Company Subdivision No. 1, Branch T.

Final Decree of Divorce Page 2 of 17

Page 85
Archer League,AbstractNo. 9, BrazoriaCounty,Texas,and being more
particularly described by metes and bounds in Document Number
2004053260 of the Deed Records of Brazoria County, Texas.

More commonly known as 107 Nesmith Place, Lots 1, 2 and 3, Surfside
Beach, Texas 77541. GEOGRAPHIC ID:6751-0006-000 AND PROPERTY
10:232468

P-3. All household furniture, furnishings, fixtures, goods, art objects, collectibles,
appliances, and equipment in the possession of Dwight L. Hill or subject to his sole
control.

P-4. All clothing, jewelry, and other personal effects in the possession of Dwight
L. Hill or subject to his sole control, including but not limited to the following:
a. Bicycle

b. Books

C. Guitar

d. Tools

e. Computer monitors x2

f. Glock26 gun

P-5. The cash on hand and funds on deposit, together with accrued but unpaid
interest, in the following banks, savings institutions, or other financial institutions:

a. PNC Bank, Checking, Account number Account ending 6618

b. PNC Bank, DLH Separate Savings,Account number Account ending
2065

c. 50% of the State Farm Federal Credit Union, Account number
Account ending 2289

d. 50% of the PNC Bank, Personal Checking,Account number Account
ending 4643

e. PNC Bank, Checking, Account number Account ending 2183

P-6. The following individual retirement accounts or portions thereof:

a. State Farm Fund Roth IRA, Account number Account ending 9211

b. The State Fann Pershing Roth IRA, Account numberAccount ending
4620 after transferring a 50% interest to Maribel L. Hill

Final Decreeof Divorce Page 3 of 17

Page 86
c. The State Farm Pershing Roth IRA, Account number Account ending
9931 after transferring a 50% interest to Maribel L. Hill

d. The Ascensus Trust IRA, Dwight Hill's Account, Account number
Account ending 2370, known as 6955, after transferring a 50%
interest to Maribel L. Hill

e. A 50% interest in Ascensus Trust IRA, Maribel Hill's Account,
Account number Account ending 2370, known as 6956

f. A 50% interest in State Farm Blackrock, Account number Account
ending C 17DN, known as 4612, currently

g. A 50% interest in State Farm Blackrock, Account number Account
ending C9ASY, known as 9964, currently

P-7. Except for those portions of Dwight L. Hill's employee and retirement
benefits in State Farm Termination Payments and .State Farm Extended Termination
Payments expressly awarded to Maribel L. Hill in this Final Decree of Divorce, all sums,
whether matured or unmatured, accrued or unaccrued, vested or otherwise, together with
all increases thereof, the proceeds therefrom, and any other rights related to any profit-
sharing plan, retirement plan, Keogh plan, pension plan, employee stock option plan,
401(k) plan, employee savings plan, accrued unpaid bonuses, disability plan, or other
benefits existing by reason of Dwight L. Hill's employment.

P-8. The following policies of insurance insuring Dwight L. Hill's life:

a. State Farm Term Life Insurance Policy, Policy number Ending 2821

P-9. The following stocks, bonds, and securities, together with all dividends,
splits, and other rights and privileges in connection with them:

a. A 50% interest in the State Farm Funds Brokerage Joint Tenants,
Account number Account ending 5608

P-10. The Honda Scooter Elite motor vehicle, together with all prepaid insurance,
keys, and title documertts.

P-11. The 2010 Lexus LX570 motor vehicle, vehicle identification number
JTJHY7AX5A4049377, together with all prepaid insurance, keys, and title documents.

P-12. 100% of Dwight L. Hill's interest in the closely held business corporation
known as Dwight Hill Insurance Agency, Inc., including but not limited to its name,
goodwill, receivables and claims, including but not limited to the funds on deposit,
together with accrued but unpaid interest, in the following bank account:

a.
PNC Bank Business Checking accoAlntenqj99 ~338. L-.. 1_
)---(1r.S~ ~~ t<-t {tHttl\\fl\~ tAIA(/ t/fu'~J- C(J!,~r.r !Je.'~3
tP,,,udtd si,,.nl;J,J;v,•J.il
,ol~O 1-76-t."'
Final Decreeof Divorce
ot fl.e_fdwf.r.r.
(J.~ 6f- Jk Jq_.k
Page4 of 17

Page 87
b. Propertyto MaribelL. Hill

IT IS ORDEREDAND DECREEDthat Respondent,MaribelL. Hill, is awardedthe
followingas her sole and separatepropertyr and Petitioner,Dwight L. Hill, is divestedof
all right,title, interest,and claim in and to that property:

R-1. The following real property,including but not limited to any escrowfunds,
prepaidinsurance, utility deposits,keys, house plans, home security access and code,
garagedoor opener,warrantiesand servicecontracts,and title and closingdocuments:
I

Lot(s) Eleven (11) and Thirteen (13) in Block Five HundredFifty-Six(556)
of SURFSIDE TOWNSITE, a subdivision in Brazoria County, Texas,
accordingto the map or plat thereof, recordedin Volume 32, Page28 of the
Deed Recordsof BrazoriaCounty, Texas.

More commonlyknownas 1211 Ft. Velasco, SurfsideBeach,Texas77541.
GEOGRAPHICID: 7875-0531-001AND PROPERTYID: 575513

R-2. 65% of the net sales proceedsfrom the sale of the following real property,
includingbut not limited to any escrow funds, prepaid insurance,utility deposits,keys,
house plans, home security access and code, garage door opener, warranties and
servicecontracts,and title and closingdocumentsand more particularlydescribedin the
11
"Sale of Real Property provisionsbelow:

Being Lots 1, 2 and 3 in Block 3 hereby subdividedout of NESMITHTract
212 in Brazos Coast InvestmentCompany Subdivision No. 1, Branch T.
Archer League,Abstract No. 9, Brazoria County, Texas, and being more
particularly described by metes and bounds in Document Number
2004053260of the Deed Recordsof BrazoriaCounty,Texas.

More commonly known as 107 Nesmith Place, Lots 1, 2 and 3, Surfside
Beach, Texas 77541. GEOGRAPHICID: 6751-006-000AND PROPERTY
ID:232468

R-3. The following real property, including but not limited to any escrowfunds,
prepaid insurance, utility deposits, keys, house plans, home security access and code,
garagedoor opener,warrantiesand servicecontracts,and title and closingdocuments:

Being a 0.08 acre tract (southeast15.00feet of Lot 1 and the northwest35
foot of Lot 2) of the Loch NesmithShores (unrecordedsubdivision)situated
in Tract 212 of the BrazosCoast InvestmentCompanySubdivisionNo. 1,
BrazoriaCounty,Texas, being the same called 0.08 acre tract conveyedto
Ronald Frankelas describedin File No. 10-014652of the Official Records
of BRAZORIACounty,Texas, said 0.08 acre tract being more particularly
describedby metes and bounds in DocumentNumber2010031228of the
Deed Recordsof BrazoriaCounty,Texas.

More commonly known as 118 Nesmith Place, Surfside Beach, Texas

Final Decreeof Divorce Page 5 of 17

Page 88
77541. GEOGRAPHIC ID: 6751-0003-000 AND PROPERT ID: 232465;
NESMITH TR 212 (A0009 BT ARCHER DIV (BC IC)) (SURFSIDE) BLK
2 LOT 1A-2A

R-4. All household furniture, furnishings, fixtures, goods, art objects, collectibles,
appliances, and equipment in the possession of Maribel L. Hill or subject to her sole
control.

R-5. All clothing, jewelry, and other personal effects in the possession of Maribel
L. Hill or subject to her sole control, including but not limited to the following:

a. Musical instruments

b. Tools

c. Sig P238 gun

d. 4.53 ct Diamond/Platinum Ring

e. Diamond necklace

f. Maribel Hill Music

g. Miscellaneous jewelry and papers in PNC Bank Safe Deposit Box

R-6. The cash on hand and funds on deposit, together with accrued but unpaid
interest, in the following banks, savings institutions, or other financial institutions:

a. 50% of the State Farm Federal Credit Union, Account number
Account ending 2289

b. 50% of the PNC Bank, Personal Checking, Account number Account
ending 4643

c. JP Morgan Chase Bank, Chase Total Checking, Account number
Account ending 2380

d. 50% of cash on hand in PNC Bank, DHIA Business Checking 3338,
which has already been distributed

R-7. The following individual retirement accounts or portions thereof:

a. State Farm Fund Roth IRA, Account number Account ending 9212

b. A 50% interest in State Farm Pershing Roth IRA, Account number
Account ending 4620

c. A 50% interest in State Farm Pershing Roth IRA, Account number
Account ending 9931

Final Decreeof Divorce Page 6 of 17

Page 89
d. A 50% interest in Ascensus Trust IRA, Dwight Hill's Account,
Account number Account ending 2370, known as 6955, currently

e. The Ascensus Trust IRA, Maribel Hill's Account, Account number
Account ending 2370 known as 6956 currently, after transferring a
50% interest to Dwight L. Hill

f. The State Farm Blackrock, Account number Account ending C17DN
known as 4612, after transferring a 50% interest to Dwight L. Hill

g. The State Farm Blackrock, Account number Account ending C9ASY
known as 9964 currently, after transferring a 50% interest to Dwight
L. Hill •

R-8. The following portion of Dwight L. Hill's State Farm Termination Payments
benefits arising out of Dwight L. Hill's employment during the marriage: 31.63% to be paid
when Dwight L. Hill retires and/or terminates and begins to receive benefits. The following
steps are to be completed prior to the signing of this divorce decree or within 3 days of
the signing of this divorce decree:

A. Dwight l:,.Hill must call Agency Sales Resource (ASR) at 833-335-0077 and
inform them he is divorced and that the Court awarded the ex-wife 31.63%
of the term and extended term pay to be paid once Dwight retires and/or
terminates;

B. Dwight L Hill will request for them to begin the process immediately to have
a QDRO or similar document of similar nature set up in order to divide the
retirement account into 2 accounts;

C. ASR will begin the process and forms will be exchanged and Dwight Hill
shall comply with all requests for information from ASR and/or the
Retirement Analyst Group and/or Legal Team of State Farm.

The benefits are to be paid directly to Maribel L. Hill from State Farm and/or their
agencies without any involvement from Dwight L. Hill other than continued cooperation
regarding the process involved with the QDRO or similar document of similar nature. The
contingent benefits to be received by Maribel Hill shall be 31.63% of the value of the term
pay as of June 20, 2024, if, as, and when received, and as further illustrated by
correspondence from State Farm dated June 20, 2024, attached hereto as Exhibit A and
incorporated by reference as if fully set forth herein, which shows the value of the term
pay as of June 20, 2024 if Dwight L. Hill were to actually have retired on May 31, 2024,
as indicated by said letter.

R-9. The following portion of Dwight L. Hill's State Farm Extended Termination
Payments benefits arising out of Dwight L. Hill's employment during the marriage: 31.63%
to be paid when Dwight L. Hill retires and/or terminates and begins to receive benefits.
The following steps are to be completed prior to the signing of this divorce decree or within
3 days of the signing of this divorce decree:

Final Decree of Divorce Page 7 of 17

Page 90
A. Dwight L. Hill must call Agency Sales Resource (ASR) at 833-335-0077 and
inform them he is divorced and that the Court awarded the ex-wife 31.63%
of the term and extended term pay to be paid once Dwight retires and/or
terminates;

B. Dwight L. Hill will request for them to begin the process immediately to have
a QDRO or similar document of similar nature set up in order to divide the
retirement account into 2 accounts;

C. ASR will begin the process and forms will be exchanged and Dwight Hill
shall comply with all requests for information from ASR and/or the
Retirement Analyst Group and/or Legal Team of State Farm.

The benefits are to be paid directly to Maribel L. Hill from State Farm and/or their
agencies without any involvement from Dwight L. Hill. The current benefits, actuarially
reduced, to be received by Maribel Hill are $1,350.28, based on 31.63% of the estimated
extended term pay of $4,269 per month which is the actuarially reduced earned amount
by Dwight Hill if terminated on May 31, 2024. The contingent benefits to be received by
Maribel Hill shall be 31.63% of the value of the extended term pay as of June 20, 2024,
if, as, and when received, and as further illustrated by correspondence from State Farm
dated June 20, 2024, attached hereto as Exhibit A and incorporated by reference as if
fully set forth herein, which shows the value of the extended term pay as of June 20, 2024
if Dwight L. Hill were to actually have retired on May 31, 2024, as indicated by said letter.

R-10. The following policies of insurance insuring Maribel L. Hill's life:

a. State Farm Term Life Insurance Policy, Policy number Ending 3643

R-11. The following stocks, bonds, and securities, together with all dividends,
splits, and other rights and privileges in connection with them:

a. A 50% interest in the State Farm Funds Brokerage Joint Tenants,
Account number Account ending 5608

R-12. The 2014 Club Car Gas xtr 850 motor vehicle, vehicle identification number
SW1523 560386, together with all prepaid insurance, keys, and title documents.

R-13. The 2021 Mazda CX-5 motor vehicle, vehicle identification number
JM3KFBCM1M1398215, together with all prepaid insurance, keys, and title documents.

R-14. 100% of parties' interest in the closely held business limited liability
company known as Restore Entertainment, LLC DBA Mousika Publishing, including but
not limited to its intellectual property, artistry, name, goodwill, receivables, claims and
money invested, including but not limited to the funds on deposit, together with accrued
but unpaid interest, in the following bank aecount:

a. Chase Bank Complete Business Checking account ending 6763

Final Decreeof Divorce Page8 of 17

Page 91
R-15. 100% of parties' interest in the closely held business limited liability
company known as Grateful Hippies LLC, including but not limited to its name, goodwill,
receivables and claims, including but not limited to the funds on deposit, together with
accrued but unpaid interest, in the following bank account:

a. PNC Bank Business Checking account ending 4123

R-16. The PNC Safe Deposit Box, Box located at PNC bank and all contents
contained ttJFr!1s ~ ~+ ~-
ah'r~ ~ l~s~4tf-~r.AJ>c,.,.,tt ~,w
i,~d.tl,,/&/i: Sfu1 l>i f.;,il,U ,u 6? ~ J,.k.!)l- .f'1..c..,.~"' .. r.er
oh!&f;'fl 1

a. Debts to Dwight L. Hill

IT IS ORDERED AND DECREED that Petitioner, Dwight L. Hill, shall timely pay,
as a part of the division of the estate of the parties, and shall indemnify and hold
Respondent, Maribel L. Hill, and her property harmless from any failure to so discharge,
these items:

P-1. The following debts, charges, liabilities, and obligations:

a. Debt, if any, owed to CapitalOne, Account number Account ending
0864

b. Debt, if any, owed to Stephen Fuqua

c. Debt, if any, owed to State Farm Federal Credit Union Line of Credit,
Account number ending 2289

P-2. All encumbrances, ad valorem taxes, liens, assessments, premiums, debts,
charges, liabilities, and other obligations incurred by Dwight L. Hill from and after June
20,2024

P-3. All encumbrances, ad valorem taxes, liens, assessments, premiums,
property taxes, or other charges due or to become due on the real and personal property
awarded to Dwight L. Hill in this Final Decree of Divorce unless express provision is made
in this Final Decree of Divorce to the contrary.

P-4. All outstanding attorney's fees, if any, owed to Epstein Family Law, P.C.

P-5. All outstanding attorney's fees, if any, owed to Armstrong Divorce and
Family Law, PLLC, up to June 20, 2024.

P-6. All outstanding attorney's fees, if any, owed to Orsinger, Nelson, Downing
and Anderson, LLP, 4.e_
to June 20, 2024.
t/JtJ?.
. P-7 35%-of all property taxes owed on 107 Nesmith, Property ID: 232468.:er AJ'?,.C(
..
p...S. ~~,,obi) et p~ ~~ -o-1 1?,11H..Vtlasu,$wf~
Final Decreeof Divorce ~Jttct
;(4 4 ~ 1 7t:'-tI . Page9 of 17

Page 92
b. Debtsto MaribelL. Hill

IT IS ORDERED AND DECREED that Respondent, Maribel L. Hill, shall timely
pay, as a part of the division of the estate of the parties, and shall indemnify and hold
Petitioner, Dwight L. Hill, and his property harmless from any failure to so discharge, these
items:

R-1. The following debts, charges, liabilities, and obligations:

a. Debt owed to Chas Bank, Account number Account ending 9682

b. Debt owed to Chase Bank, Account number Account ending 7039

R-2. All debts, charges, liabilities, and other obli~ations incurred by Maribel L.
Hill from and after June 20, 2024.

R-3. All encumbrances, ad valorem taxes, liens, assessments, premiums, o~
other charges due or to become due on the real and personal property awarded to Maribel
L. Hill in this Final Decree of Divorce unless express provision is made in this Final Decree
of Divorce to the contrary.

R-4. The balance due, including principal, interest, tax, and insurance escrow,
on the promissory note executed by Dwight L. Hill and Maribel L. Hill, payable to PNC
Bank, and secured by deed of trust on the real property awarded in this decree to Maribel
L. Hill, which is recorded in the Official Public Records of Dallas County, Texas.

IT IS ORDERED that Maribel L. Hill shall sign a Deed of Trust to Secure
Assumption for \he real pro~.!W asso9iated with the promissory note payable to PNC t
Bankct\ ~ f)ffd"e. ~f.J..t,,.,._lfRr L..
1$1 :>o:2~ if- ~~:b.e( IJ..;/1 h-4, f14
f~VVMttrJ ~ p('8~ IJr' ol,l,,"/llltf Ak 1,u" ..._,....u. ~ ~f~~ri-t-J ~ii-~ L.
R-5. All oulstandinef attorney's fees, if any, owed to Marisol Lopef,"ffp to ur.w,~, I\ l-J'1
20, 2024. tJ•lt i'o--✓ -,se,~r.v--
-R 6 60'>&of all p1ope1tytaxesowed efl 197 Heemith, Pro19er:ly
1D:232460.

9. Notice

IT IS ORDERED AND DECREED that each party shall send to the other party by
mail to the other party's last known mailing address, by email to the other party's last
known email address, or by text message to the other party's last known mobile telephone
number, within three days of its receipt, a copy of any correspondence from a creditor or
taxing authority concerning any potential liability of the other party.

10. Sale of Real Property

IT IS FURTHER ORDERED AND DECREED that the property and all
improvements located thereon Being Lots 1, 2 and 3 in Block 3 hereby subdivided out of
Tract 212 in Brazos Coast Investment Company Subdivision No. 1, Branch T. Archer

Final Decreeof Divorce Page 10 of 17

Page93
League, Abstract No. 9, Brazoria County, Texas, and being more particularly described
by metes and bounds in Document Number 2004053260 of the Deed Records of Brazoria
County, Texas, and more commonly known as 107 Nesmith Place, Lots 1, 2 and 3,
Surfside Beach, Texas 77541; GEOGRAPHIC ID: 6751-006-000 AND PROPERTY ID:
232468 ("the property"), shall be sold under the following terms and conditions:

1. The parties shall list the property with a duly licensed real estate
broker having sales experience in the area where the property is located, provided
further that the real estate broker shall be an active member in the Multiple Listing
Service with the Texas Board of Realtors, on or before July 11 2024. The real
estate broker should be an independent real estate broker who is familiar with the
properties in Surfside Beach, Texas.

2. The property shall be sold for a price that is mutually agreeable to
Petitioner and Respondent. If Petitioner and Respondent are unable to agree on
a sales price, on the application of either party, the property shall be sold under
terms and conditions determined by a court-appointed receiver.

3. The net sales proceeds (defined as the gross sales price less cost of
sale and full payment of any mortgage indebtedness or liens on the property) shall
be distributed as follows: 35% to Dwight L. Hill and 65% to Maribel L. Hill.

11. Liability for Federal Income Taxes for Prior Years

IT IS ORDERED AND DECREED that Dwight L. Hill and Maribel L. Hill shall be
equally responsible for all federal income tax lia_bilitiesof the parties allocable to the period
from the date of marriage through December 31, 2023, and each party shall timely pay
50 percent of any taxes, penalties, and interest due thereon and shall indemnify and hold
the other party and the other party's property harmless from the portion of such tax,
penalty, and interest required to be paid by the indemnifying party unless that additional
tax, penalty, or interest resulted from a party's omission of income or claim of erroneous
deduction, in which case that party shall pay, and hold the other party and the other party's
property harmless from, the additional tax, penalty, and interest allocable to the omitted
income or erroneous deduction.

IT IS ORDERED AND DECREED that if a refund of tax or other amounts is made
for any year during the parties' marriage through December 31, 2023, each party shall be
entitled to one-half of the refund amount, and the party receiving the refund _checkis
designated a constructive trustee for the benefit of the other party to the extent of one-
half of the refund amount, and the party receiving the refund check shall pay to the other
party one-half of the refund amount within five days of receipt of the refund check. Each
party is ORDERED to endorse the refund check on presentation by the other party.

12. Treatment/Allocation of Community Income for Year of Divorce

The term "I.RC." means the Internal Revenue Code of 1986, as amended.

IT IS ORDERED AND DECREED that, for the calendar year 2024, Maribel L. Hill

Final Decreeof Divorce Page 11 of 17

Page 94
will file an individual tax return 1040, after receiving the W2 from Dwight Hill Insurance
Agency, Inc. Maribel L. Hill will pay her income taxes based on her W2 in accordance
with the IRS. Maribel L. Hill will not receive a K-1 from Dwight Hill Insurance Agency, Inc.
for tax year 2024. Dwight L. Hill will file an individual federal income tax return 1040 for \ ,_
the ~lendaryear 2024, and pay any inc~me:,;r_s due unrJ,erhis personal tax retum. D~~-r
f-kll l' O'-'i
1
Ilk'} ~ws JM_ 6" IJUo..,:- IH•t ~wa-c.«.. Ar1li.q 3Aac.for ~'it.I
11 IS ORDERED AND DECREED that for calendar year 2024, eictr' party shall
indemnify and hold the other party and the other party's property harmless from any tax '""f:',t '1,~r.
liability associated with the reporting party's federal tax return for that year.

IT IS ORDERED AND DECREED that each party shall provide such information
to the other party as is requested to prepare federal income tax returns for 2024 within
thirty days of receipt of a written request for the information, and in no event shall the
available information be exchanged later than March 1, 2025. As requested information
becomes available after that date, IT IS ORDERED that it shall be provided within ten
days of receipt. IT IS FURTHER ORDERED AND DECREED that all information shall
be sent by mail to the other party's last known mailing address, by email to the other
party's last known email address, or by text message to the other party's last known
mobile telephone number.

IT IS ORDERED AND DECREED that all payments made to the other party in
accordance with the allocation provisions for payment of federal income taxes contained
in this Final Decree of Divorce are not deemed income to the party receiving those
payments but are part of the property division and necessary for a just and right division
of the parties' estate.

IT IS ORDERED AND DECREED that the parties shall cooperate with each other
and exchange all relevant information, notices, and documents in the event of an audit or
examination (or notice thereof) of their income tax returns for any period during their
marriage through the date of divorce by the Internal Revenue Service or other
governmental agency, and each party shall have the right to participate, at that participant
party's cost and expense, in that audit or examination individually or by that party's
designated representative.

13.. Confirmationof Separate Property

IT IS ORDERED AND DECREED that the following 'described property is
confirmed as the separate property of Dwight L. Hill:

P-1. The funds on deposit, together with accrued but unpaid interest, in the
following banks, savings institutions, or other financial institutions:

a. PNC Bank Checking Account, Account number Ending 1641

P-2. The following policies of insurance insuring Dwight L. Hill's life, including
cash values, if any:

a. State Farm Whdle Life Insurance Policy, Policy number Ending 2752

FinalDecreeof Divorce Page12 of 17

Page 95
b. State Farm Whole Life Insurance Policy, Policy number Ending 5601

c. State Farm Whole Life Insurance Policy, Policy number Ending 2655

d. State Farm Whole Life Insurance Policy, Policy number Ending 8176

e. State Farm Whole Life Insurance Policy, Policy number Ending 2774

P-3. The State Farm Termination Payments other than that portion awarded to
Maribel L. Hill awarded herein.

P-4. The State Farm Extended Termination Payments other than that portion
awarded to Maribel L. Hill herein.

P-5. Levovo Laptop.

P-6. Gun Cabinet with gun collection.

P-7. Gibson J45 Guitar.

IT IS ORDERED AND DECREED that the following described property is
confirmed as the separate property of Maribel L. Hill:

R-1. The following real property, including but not limited to any escrow funds,
prepaid insurance, utility deposits, keys, house plans, home security access and code,
garage door opener, warranties and service contracts, and title and closing documents:

LOT TWELVE (12)1 BLOCK B/5680 OF LINWOOD PLACE ADDITION, AN
ADDITION TO THE CITY OF DALLAS, DALLAS COUNTY, TEXAS,
ACCORDING TO THE PLAT THEREOF RECORDED IN VOLUME 31
PAGE 429, MAP RECORDS, DALLAS COUNTY, TEXAS. LINWOOD
PLACE BLK B - 5680 LT 12, ACCT#: 425713000000. SUBJECT TO ALL
EASEMENTS, COVENANTS, CONDITIONS, RESERVATIONS, LEASES
AND RESTRICTIONS OF RECORD, ALL LEGAL HIGHWAYS, ALL
RIGHTS OF WAY, ALL ZONING, BUILDING AND OTHER LAWS,
ORDINANCES AND REGULATIONS, ALL RIGHTS OF TENANTS IN
POSSESSION, AND ALL REAL ESTATE TAXES AND ASSESSMENTS
NOT YET DUE AND PAYABLE. BEING THE SAME PROPERTY
CONVEYED BY DEED RECORDED IN VOLUME 98034, PAGE 757, OF
THE DALLAS COUNTY, TEXAS RECORDS.

More commonly known as 4647 Elsby Avenue, Dallas, Texas 75209.
MARIBEL HILL IS TO ASSUME DEBT AND PAYMENT OF PNC LOAN
ACCT#: 1210015809, MORTGAGE FOR SAID PROPERlY.

14.. Confirmation of Property Gifted to Children of the Parlies

IT IS ORDERED AND DECREED that the following properties shall be gifted from

Final Decree of Divorce Page 13 of 17

Page96
the marital or separate property estate of the parties as follows:

a. Dwight L. Hill and Maribel L. Hill shall remove their names from the
PNC Bank Education Checking Account ending 2033 and put the
account solely in Ava Hill's name (ACCOUNT CLOSED);

b. The 2022 Toyota 4Runner shall be gifted to Ava Hill and the title
transferred to her name. Dwight L. Hill and Maribel L. Hill shall take
any necessary steps to transfer the title from Dwight Hill Ins Agency
and Maribel Hill to Ava Hill no later than November 1, 2024;

c. The Ford F-150 shall be gifted to Jacob Hill and the title transferred
to his name. Dwight L. Hill and Maribel L. Hill shall take any
necessary steps to transfer the title from Dwight L. Hill and Maribel
Hill to Jacob Hill;

d. The State Farm Whole Life Policy, Policy number Ending 0889 shall
be transferred to Garrett Hill as the owner on the policy;

e. The State Farm Whole Life Policy, Policy number Ending 0051 shall
be transferred to Ava Hill as the owner on the policy;

f. The State Farm Whole Life Policy, Policy number Ending 1479 shall
be transferred to Jacob Hill as the owner on the policy;

g. Dwight L. Hill and/or Maribel L. Hill shall remove their names from
the Blackrock Coverdell Account ending 2281 and put the account
solely in Ava Hilrs name;

h. Dwight L. Hill and/or Maribel L. Hill shall remove their names from
the Blackrock Coverdell Account ending 4121 and put the account
solely in Jacob Hilrs name;

i. Dwight L. Hill and/or Maribel L. Hill shall remove their names from
the State Farm Funds Coverdell Account ending 9274 and put the
account solely in Jacob Hill's name. (ACCOUNT CLOSED)

15. Credit Cards

IT IS ORDERED AND DECREED that Dwight L. Hill is granted exclusive use of
the following credit card and Maribel L. Hill is enjoined and prohibited from using or
incurring any indebtedness on that card:

a. Capital One Credit Card, Account number Ending 0864

IT IS ORDERED AND DECREED that Maribel L. Hill is granted exclusive use of
the following credit cards and Dwight L. Hill is enjoined and prohibited from using or
incurring any indebtedness on these cards:

Final Decree of Divorce Page 14 of 17

Page 97
a. Chase Bank Credit Card, Account number Ending 9682

b. Chase Bank Credit Card, Account number Ending 7039

16. Transfer and Delivery of Property

Dwight L. Hill is ORDERED to execute, have acknowledged, and deliver to Maribel
L. Hill, by and through her attorney of record, these instruments on or before ~
11, 2024: ~~ w
a. Special Warranty Deed for the 1211 Ft Velasco property; and

b. Special Warranty Deed for the 118 Nesmith Pl property.

Maribel L. Hill is ORDERED to execute, have acknowledged, and deliver to Dwight
L. Hill, by and through his attorney of record, these instruments on or before November-
>1, 2024: ~&:,v

a. Special Warranty Deed for the 123 Nesmith Pl property, attached
hereto as Exhibit 1; and

b. Deed of Trust to Secure Assumption for the 4647 Elsby Avenue ,
nA A r ft property, attached herp!~ a! Exhibit 2, .J..,~ Otobtk~ ~~~ ~
~Lw,(41 ..-. uw''d-J L. "/kit, Vl or li"Ufn.' ~Ut-\\,tr ,, ~,S u- ~"'21!{ {.. ,
This Final Decree of Divorce shall serve as a muniment of title to transfertt.,,..1 "-a
ownership of all property awarded to any party in this Final Decree of Divorce. ~ _1 .A /
1\-tr •c~w,..1,llr,/

17. Court Costs -f1..t_
{~M ~

IT IS ORDERED AND DECREED that costs of court are to be borne by the partyiJ,,,lc,.,,,./
who incurred them. Q"\ QJS~•(l

18. Discharge from Discovery Retention Reguirement JJ:k ~~ ""-"'--
IT IS ORDERED AND DECREED that the parties and their respective attorneys cµ.
are discharged from the requirement of keeping and storing the documents produced inl • fl-:A
this case in accordance with rule 191.4(d) of the Texas Rules of Civil Procedure.\_.~ ~ll"'~

19. Clarifying Orders 1, ·>D?- f.
Without affecting the finality of this Final Decree of Divorce, this Court expressly
reserves the right to make orders necessary to clarify and enforce this Final Decree of
Divorce.

20. Relief Not Granted

IT IS ORDERED AND DECREED that all relief requested in this case and not
expressly granted is denied. This is a final judgment, for which let execution and all writs
and processes necessary to enforce this judgment issue. This judgment finally disposes

Final Decree of Divorce Page 15 of 17

Page 98
of all claims and all parties and is appealable.

21. Date of Judgment

This divorce judicially PRONOUNCED AND RENDERED in court at 600
Commerce Street, Dallas County, Texas, on June ~~• and further noted on the
f/Jffl /{) I Z02f
court's docket sheet on the same date, but signed on .JLL,.it_llA

Final Decreeof Divorce Page 16 of 17

Page 99
APPROVEDAS TO FORMONLY:

EPSTEINFAMILYLAW, P.C.
5949 SherryLane, Suite 1070
Dallas, TX 75225
Tel: (972) 232-7673

obert D. Epstein
State Bar No. 24065206
robert@epsteinpc.com
Attorneyfor DwightL. Hill

Marisol Lopez
SBN: 24050952
301 W. Avenue D
Garland, Texas 75040
972-205-1110 office phone
1-866-232-2077 facsimile
Marisol@lawyerforu.com
Attorney for Maribel L. Hill

Final Decree of Divorce Page 17 of 17

Page 100
A StateFarm,
June 20, 2024

Hill, DwightL
4647 ElsbyAve
Dallas,TX 75209-3203

Dear Dwight,

Following is a review of your estimated Termination and Extended Termination Payments you requested. Section IV,
Paragraph 8 of the Agent's Agreement reviews the qualifications that must be met in order for Termination Payments to be
made. In order for Termination Payments to be made, the Agent's Agreement must be terminated. The agent will return,
or make available for return, Company property within 10 days of the termination of the agreement. In addition, the agent
agrees to not induce, advise, or solicit any State Farm policyholders in his account at the time of his termination. The agent
also agrees to not act or represent himself in any way as an agent or representative of the Companies. Please see Section
111,
Termination of Agreement, of the Agent's Agreement for a more thorough review of Termination provisions.

The following are your estimated monthly Termination and Extended Termination Payments by company assuming a
5/31/2024 termination date. Term payments will be made for 60 months following your termination.

Term Pay Ext Term Pay
Auto Voluntary $2,640 $2,640
Auto TCM $19 $0
Fire $206 $201
Lloyds $3,763 $3,737
Fire TCM $131 $131
Health $22 $0
Life $107 $107
Total $6,888 $6,816

NOTE: Extended Termination pay is available to agents who are 60 years or older with 20 years of service (last 10
continuous). Please remember that if you terminate prior to age 65, your Extended Termination Payments will be
actuarially reduced. Extended termination payments are also available for those agents who meet the terms of the Early
Notification Program. Under the Early Notification Program, you can qualify for Extended Termination payments at age 55
if (1) you are at least 55 years old, with 20 years of service (last 10 continuous) OR (2) age plus years of service equals
80.

Extended Termination amounts will be actuarially reduced for retirement before age 65. For retirement at age 59
years 7 months, the actuarial factor of 0.6263 reduces your Extended Termination payments to $4,269 a month. If you
elect the joint and 2/3 survivor option, the extended term amount would be further adjusted to $3,625 a month. The
survivor amount would be $2,417 a month.

NOTE: Life Writing Compensation Payments are based on writing compensation that would have been paid to you if
your Agreement had not been terminated. Life Writing Compensation Payments will fluctuate each month depending
on premium paid each month following termination and payments are reduced by a decreasing commission scale as
business ages and any lapsed/cancelled policies.

NOTE: All figures are estimates. Contract provisions will govern actual amounts.

Attached is the estimate you requested. If you have any additional questions or concerns, please contact an ASR
Representative at 1-833-335-0077 and follow the prompts to contracts and compensation.

Our hours of ope.ration are 7am to 7 pm central time, Monday through Friday.

Sincerely,
Agency/Sales Resources

Page 101
EXHIBIT

1
Special Warranty Deed

Notice of confidentiality rights: If you are a natural person, you may remove or
strike any or all of the following information from any instrument that transfers an
interest in real property before it is filed for record in the public records: your
Social Security number or your driver's license number.

Date: ____ _.2024

Grantor: Maribel L. Hill

Grantor'sMailingAddress:

4647 Elsby Avenue
Dallas, Texas 75209
Dallas County

Grantee: Dwight L. Hill

Grantee'sMailingAddress:

10300 N. Central Expressway, #296
Dallas, Texas 75231
Dallas County

Consideration:

The division of property ordered by the 302nd Judicial District Court of Dallas

County, Texas, in Cause No. DF-22-14398, styled "In the Matter of the Marriage of

Dwight L. Hill and Maribel L. Hill and in the Interest of J.L.H., A Child," and ten dollars

and other valuable consideration paid by Grantee.

Property(includingany improvements):

LOT TWELVE (12), BLOCK TWO (2), SURFSIDE, CONSISTING OF 0.080
ACRES OF LAND, MORE OR LESS, HEREBY SUBDIVIDED OUT OF TRACT
212, OUT OF BRAZOS COAST INVESTMENT COMPANY SUBDIVISION NO.
1, BRANCH T. ARCHER LEAGUE, ABSTRACT 9, BRAZORIA COUNTY,
TEXAS, AND BEING MORE PARTICULARLY DESCRIBED BY METES AND
BOUNDS IN VOLUME 1772, PAGE 276 OF THE DEED RECORDS OF
BRAZORIA COUNTY, TEXAS. (ACCOUNT NUMBER 6751-002-110}

More commonly known as 123 Nesmith Place, Surfside Beach, Texas 77541.

Special Warranty Deed - 123 Nesmith Place Page 1 of 3

Page 102
Reservationsfrom Conveyanceand Exceptionsto Conveyanceand Warranty:

This deed is subject to all easements, restrictions, conditions, covenants, and

other instruments of record.

Conveyance:

Grantor, for the consideration and subject to the reservations from conveyance

and exceptions to conveyance and warranty, grants, sells, and conveys to Grantee all of

Grantor's interest in the property, together with all and singular the rights and

appurtenances thereto in any way belonging, to have and hold it to Grantee and

Grantee's heirs, successors, and assigns forever. Granter binds Grantor and Grantor's

heirs and successors to warrant and forever defend all and singular the property to

Grantee and Grantee's heirs, successors, and assigns against every person

whomsoever lawfully claiming or to claim the same or any part thereof when the claim is

~by, through, or under Granter but not otherwise, except as to the reservations from

conveyance and exceptions to conveyance and warranty.

Grantor assigns to Grantee the casualty insurance policy on the property, all

utility deposits for utility services at the property, and all funds held in escrow for

payment of taxes and insurance premiums.

When the context requires, singular nouns and pronouns include the plural.

Grantee assumes all ad valorem taxes due on the property for the current year.

MaribelL. Hill

This instrument was prepared based on
information furnished by the parties, and no
independent title search has been made.

SpecialWarranty Deed - 123 NesmithPlace Page 2 of 3

Page 103
STATE OF TEXAS §

COUNTY OF DALLAS §

This instrument was acknowledged before me on
by Maribel L. Hill.

Notary Public, State of Texas

SpecialWarrantyDeed- 123 Nesmith Place Page 3of3

Page 104
EXHIBIT

2

Deed of Trust to Secure Assumption

Basic Information

Date: ------ ,2024

Grantor: Maribel L. Hill

Grantor'sMailingAddress:

4647 Elsby Avenue
Dallas, Texas 75209
Dallas County

Trustee: Robert D. Epstein

Trustee'sMailingAddress:

5949 Sherry Lane, Suite 1070
Dallas, Texas 75225
_DallasCounty

Beneficiary: Dwight L. Hill

Beneficiary'sMailingAddress:

10300 N. Central Expressway, #296
Dallas, Texas 75231
Dallas County

Note and Deed of Trust Assumed:

Date: May 17, 2013

Original pr_incipalamount: $336,000.00

Maker and Grantor: Dwight L. Hill and Maribel L. Hill

Payee and Beneficiary: Compass Bank, now known as PNC Bank
Loan number 1210015809

Recording infonnation: Instrument Number 201300161422;
Dallas County Deed Records

Property(including any improvements):

Deed of Trust to Secure Assumption - Elsby Page 1 of 8

Page 105
LOT TWELVE (12), BLOCK B/5680 OF LINWOOD PLACE ADDITION, AN
ADDITION TO THE CITY OF DALLAS, DALLAS COUNTY, TEXAS,
ACCORDING TO THE PLAT THEREOF RECORDED IN VOLUME 3, PAGE
429, MAP RECORDS, DALLAS COUNTY, TEXAS. LINWOOD PLACE BLK 8 -
5680 LT 12, ACCT #: 425713000000. SUBJECT TO ALL EASEMENTS,
COVENANTS, CONDITIONS, RESERVATIONS, LEASES AND
RESTRICTIONS OF RECORD, ALL LEGAL HIGHWAYS, ALL RIGHTS OF
WAY, ALL ZONING, BUILDING AND OTHER LAWS, ORDINANCES AND
REGULATIONS, ALL RIGHTS OF TENANTS IN POSSESSION, AND ALL REAL
ESTATE TAXES AND ASSESSMENTS NOT YET DUE AND PAYABLE. BEING
THE SAME PROPERTY CONVEYED BY DEED RECORDED IN VOLUME
98034, PAGE 757, OF THE DALLAS COUNTY, TEXAS RECORDS.

More commonly known as 4647 Elsby Avenue, Dallas, Texas 75209.

Prior Lien: •None

Other Exceptions to Conveyance and Warranty: None

Consideration: Beneficiary has conveyed the property to Granter, who as part of

the consideration promised to pay the note assumed and to be· bound by the deed of

trust assumed.

A. Granting Clause

For value received and to secure Grantor's assumption, Granter conveys the

property to Trustee in trust. Grantor warrants and agrees to defend the title to the

property, subject to the other exceptions to conveyance and warranty. If Granter

performs all the covenants of the note and deed of trust assumed and if Beneficiary has

not filed a notice of advancement, a release of the deed of trust assumed will release

this deed of trust to secure assumption and Beneficiary's vendor's lien.

B. Grantor's Obligations

Grantor agrees to -

B.1. perform all the covenants of the Note and Deed of Trust assumed; and

B.2. notify Beneficiary and Lender of any change of address.

Deed of Trust to Secure Assumption - Elsby Page2 of 8

Page 106
C. Beneficiary'sRights

C.1. Beneficiary may appoint in writing a substitute trustee, succeeding to all

rights and responsibilities of Trustee.

C.2. If Granter fails to perform any of Grantor's obligations under the note

assumed or deed of trust assumed, Beneficiary may perform those obligations, advance

funds required, and then be reimbursed by Granter on demand for any amounts so

advanced, including attorney's fees, plus interest on those amounts from the dates of

payment at the highest legal rate. The amount to be reimbursed will be secured by this

deed of trust to secure assumption.

C.3. Beneficiary may file a sworn notice of such advancement in the office of

the county clerk in the county in which the property is located. The notice will detail the

dates, amounts, and purposes of the amounts advanced and the legal description of the

property.

C.4. If Granter fails on demand to reimburse Beneficiary for the amounts

advanced and such failure conti~ues after Beneficiary gives Granter notice of the failure

and the time within which it must be cured, to the extent required by law or by written

agreement, Beneficiary may -

a. exercise Beneficiary's rights with respect to rent under the Texas

Property Code as then in effect;

b. direct Trustee to foreclose this lien, in which case Beneficiary or

Beneficiary's agent will cause notice of the foreclosure sale to be

given as provided by the_Texas Property Code as then in effect;

and

Deed of Trust to Secure Assumption ~ Elsby Page 3 of 8

Page 107
c. purchase the property at any foreclosure sale by offering the

highest bid and then have the bid credited to the amount owed to

Beneficiary.

D. Trustee'sRightsand Duties

If directed by Beneficiaryto foreclose this lien, Trustee will-

D.1. either personally or by agent give notice of the foreclosure sale as

required by this deed of trust to secure assumption and the Texas Property Code as

then in effect;

D.2. sell and convey all or part of the property "AS IS" to the highest bidder for

cash with a general warranty binding Granter, subject to the prior lien and to the other

exceptions to conveyance and warranty and without representationor warranty, express

or implied, by Trustee;

D.3. from the proceeds of the sale, pay, in this order-

a. expenses of foreclosure, including a reasonable commission to

Trustee;

b. to Beneficiary, the full amount advanced, attorney's fees, and other

charges due and unpaid;

c. any amounts required by law to be paid before payment to Granter;

and

d. to Granter, any balance; and

D.4. be indemnified, held harmless, and defended by Beneficiary against all

costs, expenses, and liabilities incurred by Trustee for acting in the execution or

enforcement of the trust created by this deed of trust to secure assumption, which

Deed of Trust to SecureAssumption- Elsby Page 4 of 8

Page 108
includes all court and other costs, including attorney's fees, incurred by Trustee in

defense of any action or proceeding taken against Trustee in that capacity.

E. General Provisions

E.1. If any of the property is sold under this deed of trust to secure assumption,

Granter must immediately surrender possession to the purchaser. If Granter does not,

Granter will be a tenant at sufferance of the purchaser, subject to an action for forcible

detainer.

E.2. Recitals in any trustee's deed conveying the property will be presumed to

be true.

E.3. Proceeding under this deed of trust to secure assumption, filing suit for

foreclosure, or pursuing any other remedy will not constitute an election of remedies.

E.4. This lien will be superior to liens later created even if Beneficiary has

made no advancementswhen later liens are created.

E.5. If any portion of the advancements cannot be lawfully secured by this

deed of trust to secure assumption, payments will be applied first to discharge that

portion.

E.6. A sale of the property under this deed of trust to secure assumption-

a. is subject to Grantor's continuing obligation to make all payments

owing on the note assumed and to perform all obligations under the

deed of trust assumed; and

b. does not extinguish Trustee's right to conduct subsequent sales of

the property for future Granter defaults under this deed of trust to

secure assumption.

Deed of Trust to Secure Assumption - Elsby Page 5 of 8

Page 109
E.7. Grantor collaterally assigns to Beneficiary all present and future rent from

the property and its proceeds. Grantor warrants the validity and enforceability of the

assignment. Grantor will apply all rent to payment of the note assumed and

performance of the deed of trust assumed, but if the rent exceeds the amount due with

respect to. the note and deed of trust assumed, Granter may retain the excess. If a

default exists in payment of the note assumed or performance of this deed of trust to

secure assumption or of the deed of trust assumed, Beneficiary may exercise

Beneficiary's rights with respect to rent under the Texas Property Code as then in effect.

Beneficiary neither has nor assumes any obligations as lessor or landlord with respect

to any occupant of the property. Beneficiary may exercise Beneficiary's rights and

remedies under this paragraph without taking possession of the property. Beneficiary

will apply all rent collected under this paragraph as required by the Texas Property

Code as then in effect. Beneficiary is not required to act under this paragraph, and

acting under this paragraph does not waive any of Beneficiary's other rights or

remedies.

E.8. Interest on the debt secured by this deed of trust to secure assumption will

not exceed the maximum amount of nonusurious interest that may be contracted for,

taken, reserved, charged, or received under law. Any interest in excess of that

maximum amount will be credited on the principal of the debt or, if that has been paid,

refunded. On any acceleration or required or permitted prepayment, any such excess -

will be canceled automatically as of the acceleration or prepayment or, if already paid,

credited on the principal of the debt or, if the principal of the debt has been paid,

refunded. This provision overrides any conflicting provisions in this and all other

Deed of Trust to Secure Assumption - Elsby Page 6of 8

Page 110
instruments concerning the debt.

E.9. Any action taken under this deed of trust to secure assumption will not

extinguish the rights of Beneficiary to proceed against Granter under the indemnity

contained in the deed by which Granter assumed the note and deed of trust assumed.

E.10. When the context requires, singular nouns and pronouns include the

plural.

E.11. This deed of trust to secure assumption binds, benefits, and may be

enforced by the successors in interest of all parties.

E.12 Granter waives and surrenders to Beneficiary (a) Grantor's power to

authorize anyone (other than Beneficiary or Grantor) to pay ad valorem taxes on the

property and {b) Grantor's power to authorize a taxing entity to transfer its tax lien on the

property to anyone other than Beneficiary. Granter agrees and declares that any

authorization from Granter to another (other than Beneficiary) to pay the taxes and

transfer a tax lien on the property is void.

E.13. If all or any part of the property is sold, conveyed, leased for a period

longer than three years, leased with an option to purchase, or otherwise sold (including

any contract for deed) without Beneficiary's prior written consent, which consent may be

withheld in Beneficiary's sole discretion, Beneficiary may declare a default of this

agreement and seek to foreclose on the property. The creation of a subordinate lien,

any conveyance under threat or order of condemnation, or the passage of title by

reason of the death of Granter or by operation of law will not entitle Beneficiary to

exercise the remedies provided in this paragraph.

E.14. Granter agrees to provide proof of payment (including escrows) of all

Deed of Trust to Secure Assumption - Elsby Page 7 of 8

Page 111
obligations paid under the assumed note to Beneficiary on request. Granter and

Beneficiary agree to provide each other with ongoing access to all passwords and

ongoing online access related to the assumed note. Granter and Beneficiary agree to

forward a copy of any and all correspondence from the underlying Lender to the other

party within five business days of receipt.

MaribelL. Hill

This instrument was prepared based on
information furnished by the parties, and no
independent title search has been made.

STATEOF TEXAS )

COUNTYOF DALLAS )

This instrument was acknowledged before me on _________ by
Maribel L. Hill.

Notary Public, State of Texas

Deed of Trust to SecureAssumption- Elsby Page 8 of 8

Page 112
&State Farm,

June20, 2024

Hill, DwightL
4647 ElsbyAve
Dallas,TX 75209-3203

Dear Dwight,

Following is a review of your estimated Termination and Extended Termination Payments you requested. Section IV,
Paragraph B of the Agent's Agreement reviews the qualifications that must be met in order for Termination Payments to be
made. In order for Termination Payments to be made, the Agent's Agreement must be terminated. The agent will return,
or make available for return, Company property within 10 days of the termination of the agreement. In addition, the agent
agrees to not induce, advise, or solicit any State Farm policyholders in his account at the time of his termination. The agent
also agrees to not act or represent himself in any way as an agent or representative of the Companies. Please see Section
Ill, Termination of Agreement, of the Agent's Agreement for a more thorough review of Termination provisions.

The following are your estimated monthly Termination and Extended Termination Payments by company assuming a
5/31/2024 termination date. Term payments will be made for 60 months following your termination.

Term Pay Ext Term Pay
Auto Voluntary $2,640 $2,640
Auto TCM $19 $0
Fire $206 $201
Lloyds $3,763 $3,737
Fire TCM $131 $131
Health $22 $0
Life $107 $107
Total $6,888 $6,816

NOTE: Extended Termination pay is available to agents who are 60 years or older with 20 years of service (last 10
continuous). Please remember that if you terminate prior to age 65, your Extended Termination Payments will be
actuarially reduced. Extended termination payments are also available for those agents who meet the terms of the Early
Notification Program. Under the Early Notification Program, you can qualify for Extended Termination payments at age 55
if (1) you are at least 55 years old, with 20 years of service (last 1O continuous) OR (2) age plus years of service equals
80.

Extended Termination amounts will be actuarially reduced for retirement before age 65. For retirement at age 59
years 7 months, the actuarial factor of 0.6263 reduces your Extended Termination payments to $4,269 a month. If you
elect the joint and 2/3 survivor option, the extended term amount would be further adjusted to $3,625 a month. The
survivor amount would be $2,417 a month.

NOTE: Life Writing Compensation Payments are based on writing compensation that would have been paid to you if
your Agreement had not been terminated. Life Writing Compensation Payments will fluctuate each month depending
on premium paid each month following termination and payments are reduced by a decreasing commission scale as
business ages and any lapsed/cancelled policies.

NOTE: All figures are estimates. Contract provisions will govern actual amounts.

Attached is the estimate you requested. If you have any additional questions or concerns, please contact an ASR
Representative at 1-833-335-0077 and follow the prompts to contracts and compensation.

Our hours of operation are 7am to 7 pm central time, Monday through Friday.

Sincerely,
Agency/Sales Resources

Page 101
EXHIBIT

1
Special Warranty Deed

Notice of confidentiality rights: If you are a natural person, you may remove or
strike any or all of the following information from any instrument that transfers an
interest in real property before it is filed for record in the public records: your
Social Security number or your driver's license number.

Date: ------ 2024

Grantor: Maribel L. Hill

Grantor'sMailingAddress:

4647 Elsby Avenue
Dallas1 Texas 75209
Dallas County

Grantee: Dwight L. Hill

Grantee'sMailingAddress:

10300 N. Central Expressway, #296
Dallas Texas 75231
1

Dallas County

Consideration:

The division of property ordered by the 302nd Judicial District Court of Dallas

County1 Texas, in Cause No. DF-22-14398, styled "In the Matter of the Marriage of

Dwight L. Hill and Maribel L. Hill and in the Interest of J.L.H., A Child," and ten dollars

and other valuable consideration paid by Grantee.

Property(includingany improvements):

LOT TWELVE (12), BLOCK lWO (2), SURFSIDE, CONSISTING OF 0.080
ACRES OF LAND, MORE OR LESS, HEREBY SUBDIVIDED OUT OF TRACT
212, OUT OF BRAZOS COAST INVESTMENT COMPANY SUBDIVISION NO.
1, BRANCH T. ARCHER LEAGUE, ABSTRACT 9, BRAZORIA COUNTY,
TEXAS, AND BEING MORE PARTICULARLY DESCRIBED BY METES AND
BOUNDS IN VOLUME 1772, PAGE 276 OF THE DEED RECORDS OF
BRAZORIA COUNTY, TEXAS. (ACCOUNT NUMBER 6751-002-110}

More commonly known as 123 Nesmith Place, Surfside Beach, Texas 77541.

Special Warranty Deed - 123 Nesmith Place Page 1 of 3

Page 102
Reservationsfrom Conveyanceand Exceptionsto Conveyanceand Warranty:

This deed is subject to all easements, restrictions, conditions, covenants, and

other instruments of record.

Conveyance:

Granter, for the consideration and subject to the reservations from conveyance

and exceptions to conveyance and warranty, grants, sells, and conveys to Grantee all of

Grantor's interest in the property, together with all and singular the rights and

appurtenances thereto in any way belonging, to have and hold it to Grantee and

Grantee's heirs, successors, and assigns forever. Granter binds Granter and Grantor's

heirs and successors to warrant and forever defend all and singular the property to

Grantee and Grantee's heirs, successors, and assigns against every person

whomsoever lawfully claiming or to claim the same or any part thereof when the claim is

by, through, or under Grantor but not otherwise, except as to the reservations from

conveyance and exceptions to conveyance and warranty.

Granter assigns to Grantee the casualty insurance policy on the property, all

utility deposits for utility services at the property, and all funds held in escrow for

payment of taxes and insurance premiums.

When the context requires, singular nouns and pronouns include the plural.

Grantee assumes all ad valorem taxes due on the property for the current year.

Maribel L. Hill

This instrument was prepared based on
information furnished by the parties, and no
independent title search has been made.

SpecialWarranty Deed - 123 NesmithPlace Page 2 of3

Page 103
STATEOF TEXAS §

COUNTYOF DALLAS §

This instrument was acknowledged before me on
by Maribel L. Hill.

NotaryPublic,State of Texas

SpecialWarrantyDeed- 123 NesmithPlace Page 3 of 3

Page 104
EXHIBIT

2

Deed of Trust to Secure Assumption

Basic Information

Date: _____ _,2024

Granter: Maribel L. Hill

Grantor's Mailing Address:

4647 Elsby Avenue
Dallas,Texas75209
Dallas County

Trustee: Robert D. Epstein

Trustee's Mailing Address:

5949 Sherry Lane, Suite 1070
Dallas, Texas 75225
_DallasCounty

Beneficiary: Dwight L. Hill

Beneficiary's Mailing Address:

10300 N. Central Expressway, #296
Dallas, Texas 75231
Dallas County

Note and Deed of Trust Assumed:

Date: May 17, 2013

Original p~incipalamount: $336,000.00

Maker and Grantor: Dwight L. Hill and Maribel L. Hill

Payee and Beneficiary: Compass Bank, now known as PNC Bank
Loan number 1210015809

Recording information: Instrument Number 201300161422;
Dallas County Deed Records

Property (including any improvements):

Deed of Trust to SecureAssumption- Elsby Page 1 of 8

Page 105
LOT TWELVE (12), BLOCK B/5680 OF LINWOOD PLACE ADDITION, AN
ADDITION TO THE CITY OF DALLAS, DALLAS COUNTY, TEXAS,
ACCORDING TO THE PLAT THEREOF RECORDED IN VOLUME 3, PAGE
429, MAP RECORDS, DALLAS COUNTY, TEXAS. LINWOOD PLACE BLK 8 -
5680 LT 12, ACCT #: 425713000000. SUBJECT TO ALL EASEMENTS,
COVENANTS, CONDITIONS, RESERVATIONS, LEASES AND
RESTRICTIONS OF RECORD, ALL LEGAL HIGHWAYS, ALL RIGHTS OF
WAY, ALL ZONING, BUILDING AND OTHER LAWS, ORDINANCES AND
REGULATIONS, ALL RIGHTS OF TENANTS IN POSSESSION, AND ALL REAL
ESTATE TAXES AND ASSESSMENTS NOT YET DUE AND PAYABLE. BEING
THE SAME PROPERTY CONVEYED BY DEED RECORDED IN VOLUME
98034, PAGE 757, OF THE DALLAS COUNTY, TEXAS RECORDS.

More commonly known as 4647 Elsby Avenue, Dallas, Texas 75209.

Prior Lien: -None

Other Exceptions to Conveyance and Warranty: None

Consideration: Beneficiary has conveyed the property to Grantor, who as part of

the consideration promised to pay the note assumed and to be· bound by the deed of

trust assumed.

A. Granting ~lause

For value received and to secure Grantor's assumption, Granter conveys the

property to Trustee in trust. Granter warrants and agrees to defend the title to the

property, subject to the other exceptions to conveyance and warranty. If Granter

performs all the covenants of the note and deed of trust assumed and if Beneficiary has

not filed a notice of advancement, a release of the deed of trust assumed will release

this deed of trust to secure assumption and Beneficiary's vendor's lien.

B. Grantor's Obligations

Granter agrees to-

B.1. perform all the covenants of the Note and Deed of Trust assumed; and

8.2. notify Beneficiary and Lender of any change of address.

Deed of Trust to Secure Assumption - Elsby Page2 of8

Page 106
C. Beneficiary'sRights

C.1. Beneficiary may appoint in writing a substitute trustee, succeeding to all

rights and responsibilities of Trustee.

C.2. If Granter fails to perform any of Grantor's obligations under the note

assumed or deed of trust assumed, Beneficiary may perform those obligations, advance

funds required, and then be reimbursed by Grantor on demand for any amounts so

advanced, including attorney's fees, plus interest on those amounts from the dates of

payment at the highest legal rate. The amount to be reimbursed will be secured by this

deed of trust to secure assumption.

C.3. Beneficiary may file a sworn notice of such advancement in the office of

the county clerk in the county in which the property is located. The notice will detail the

dates, amounts, and purposes of the amounts advanced and the legal description of the

property.

C.4. If Granter fails on demand to reimburse Beneficiary for the amounts

advanced and such failure conti~ues after Beneficiary gives Granter notice of the failure

and the time within which it must be cured, to the extent required by law or by written

agreement, Beneficiary may -

a. exercise Beneficiary's rights with respect to rent under the Texas

Property Code as then in effect;

b. direct Trustee to foreclose this lien, in which case Beneficiary or

Beneficiary's agent will cause notice of the foreclosure sale to be

given as provided by the_Texas Property Code as then in effect;

and

Deed of Trust to Secure Assumption - Elsby Page 3 of 8

Page 107
c. purchase the property at any foreclosure sale by offering the

highest bid and then have the bid credited to the amount owed to

Beneficiary.

D. Trustee's Rightsand Duties

If directed by Beneficiary to foreclose this lien, Trustee will-

D.1. either personally or by agent give notice of the foreclosure sale as

required by this deed of trust to secure assumption and the Texas Property Code as

then in effect;

D.2. sell and convey all or part of the property "AS IS" to the highest bidder for

cash with a general warranty binding Grantor, subject to the prior lien and to the other

exceptions to conveyance and warranty and without representationor warranty, express

or implied, by Trustee;

D.3. from the proceeds of the sale, pay, in this order -

a. expenses of foreclosure, including a reasonable commission to

Trustee;

b. to Beneficiary, the full amount advanced, attorney's fees, and other

charges due and unpaid;

c. any amounts required by law to be paid before payment to Granter;

and

d. to Grantor, any balance; and

D.4. be indemnified, held harmless, and defended by Beneficiary against all

costs, expenses, and liabilities incurred by Trustee for acting in the execution or

enforcement of the trust created by this deed of trust to secure assumption, which

Deed of Trust to Secure Assumption - Elsby Page 4of8

Page 108
includes all court and other costs, including attorney's fees, incurred by Trustee in

defense of any action or proceeding taken against Trustee in that capacity.

E. GeneralProvisions

E.1. If any of the property is sold under this deed of trust to secure assumption,

Grantor must immediately surrender possession to the purchaser. (.f Granter does not,

Grantor will be a tenant at sufferance of the purchaser, subject to an action for forcible

detainer.

E.2. Recitals in any trustee's deed conveying the property will be presumed to

be true.

E.3. Proceeding under this deed of trust to secure assumption, filing suit for

foreclosure, or pursuing any other remedy will not constitute an election of remedies.

E.4. This lien will be superior to liens later created even if Beneficiary has

made no advancementswhen later liens are created.

E.5. If any portion of the advancements cannot be lawfully secured by this

deed of trust to secure assumption, payments will be applied first to discharge that

portion.

E.6. A sale of the property under this deed of trust to secure assumption-

a. is subject to Grantor's continuing obligation to make all payments

owing on the note assumed and to perform all obligations under the

deed of trust assumed; and

b. does not extinguish Trustee's right to conduct subsequent sales of

the property for future Granter defaults under this deed of trust to

secure assumption.

Deed of Trust to Secure Assumption - Elsby Page 5 of 8

Page 109
E.7. Granter collaterally assigns to Beneficiary all present and future rent from

the property and its proceeds. Granter warrants the validity and enforceability of the

assignment. Grantor will apply all rent to payment of the note assumed and

performance of the deed of trust assumed, but if the rent exceeds the amount due with

respect to. the note and deed of trust assumed, Granter may retain the excess. If a

default exists in payment of the note assumed or performance of this deed of trust to

secure assumption or of the deed of trust assumed, Beneficiary may exercise

Beneficiary's rights with respect to rent under the Texas Property Code as then in effect.

Beneficiary neither has nor assumes any obligations as lessor or landlord with respect

to any occupant of the property. Beneficiary may exercise Beneficiary's rights and

remedies under this paragraph without taking possession of the property. Beneficiary

will apply all rent collected under this paragraph as required by the Texas Property

Code as then in effect. Beneficiary is not required to act under this paragraph, and

acting under this paragraph does not waive any of Beneficiary's other rights or

remedies.

E.8. Interest on the debt secured by this deed of trust to secure assumption will

not exceed the maximum amount of nonusurious interest that may be contracted for,

taken, reserved, charged, or received under law. Any interest in excess of that

maximum amount will be credited on the principal of the debt or, if that has been paid,

refunded. On any acceleration or required or permitted prepayment, any such excess·

will be canceled automatically as of the acceleration or prepayment or, if already paid,

credited on the principal of the debt or, if the principal of the debt has been paid,

refunded. This provision overrides any conflicting provisions rn this and all other

Deedof Trustto SecureAssumption- Elsby Page6 of 8

Page 110
instruments concerning the debt.

E.9. Any action taken under this deed of trust to secure assumption will not

extinguish the rights of Beneficiary to proceed against Granter under the indemnity

contained in the deed by which Granter assumed the note and deed of trust assumed.

E.10. When the context requires, singular nouns and pronouns include the

plural.

E.11. This deed of trust to secure assumption binds, benefits, and may be

enforced by the successors in interest of all parties.

E.12 Granter waives and surrenders to Beneficiary (a) Grantor's power to

authorize anyone (other than Beneficiary or Granter) to pay ad valorem taxes on the

property and (b) Grantor's power to authorize a taxing entity to transfer its tax lien on the

property to anyone other than Beneficiary. Granter agrees and declares that any

authorization from Granter to another (other than Beneficiary) to pay the taxes and

transfer a tax lien on the property is void.

E.13. If all or any part of the property is sold, conveyed, leased for a period

longer than three years, leased with an option to purchase, or otherwise sold (including

any contract for deed) without Beneficiary's prior written consent, which consent may be

withheld in Beneficiary's sole discretion, Beneficiary may declare a default of this

agreement and seek to foreclose on the property. The creation of a subordinate lien,

any conveyance under threat or order of condemnation, or the passage of title by

reason of the death of Granter or by operation of law will not entitle Beneficiary to

exercise the remedies provided in this paragraph.

E.14. Granter agrees to provide proof of payment (including escrows) of all

Deed of Trust to Secure Assumption - Elsby Page 7 of 8

Page 111
obligations paid under the assumed note to Beneficiary on request. Grantor and

Beneficiary agree to provide each other with ongoing access to all passwords and

ongoing online access related to the assumed note. Grantor and Beneficiary agree to

forward a copy of any and all correspondence from the underlying Lender to the other

party within five business days of receipt.

MaribelL. Hill

This instrument was prepared based on
information furnished by the parties, and no
independent title search has been made.

STATE OF TEXAS )

COUNTY OF DALLAS )

This instrument was acknowledged before me on _________ by
Maribel L. Hill.

Notary Public, State of Texas

Deed of Trust to Secure Assumption - Elsby Page 8of 8

Page 112
EXHIBITD

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I. D f.HA l. 0 RHS J. CE)CouvUnit\:: 6. File Num.l.)cr
,1. Dv;, ·1.l.o>nNu:nbcr , 8. Mo:in,,~c
InsOise Number
5. D Cor.v Int. 6. D Stlkr :=in 13.?2i20-,\L,ND G710099292
c,..
7. D h Sole.

C.No!:: Th~formis 01r,1id1td
to GiveYot1:\ :tntcmcnt
of t1Ctull costs .Amour.ts
scrtlcmenl µaidlo tmdby1h:settlement
I
!l31:11l
tre shown.l:e:rutntrkcd
•(n o.c.)I'weren:iicJ
01111ide
lhe clc11i1:tt:
th:y ere :showo
hen:::
for in(orme101101
n1uo0.1e1
n,,~nrenot fnolutlcdin ihc I0l!ls.
D. NomeS;.Adwcs, orilormwcr & Addrm of Seler
E. N11mc F. Nome& Addren of under
llwir:hr 1...Mm ::amlMadt:cl t... mu
.JG,:7l!l!by i\ve1111, Comp:usIlonlt
70! S. J?u~ Srrcct
0:1!1:1s,
TX 75209
Birml11ehnn1.AL J523J

0. Propertylc<,U0!l H. Scliluntnt Asent Non} I Seu.temcn1 D!te
,\llcglnncoTIiie Conipo, • 5/11/lOlJ
Lif\\t"O¢d
.Ph::cc.Ulct1:D/5680, Lot 12-,Col!ht 81J l Pmtor, Rond, Sult JOO
County
•1447Bisby,\\'Cnth!
o,11n,,'fX 75225
21~6J5l100
J Fo::,d:51'..lt!0IJ

Oolla,, TX 7520? Tiv:1111c c.so,1rc:c1
U11de11rriUc1t
J>loceof Scnfcmtnt l
/\llccinri,cTille Compni:•• Nor1ilO•llos
I SiiO N. D•llns Pnl'lnv•. ,1/l!00
U:iH,.,, TX 7.52-18
J J, Sun:1nnryor Dorrow:r'sTrons,01!011 I
100.C1·oss .At1:0~1r1,Out IroinDorrcwc:·
( IC.S11mn1:1ry
ofScUet..J Trnus:u:tlcr.
I
-ICO.Crou ArnountOu:.ro StUcr
lOJ. Conl~et!11lc:1
r,rice 10I. Comrncl!olc.sprice
102 Pc:so11nl prorcny 402. Penonn.11>roµcsty
chnrces
103, Setlle.··nciu to borrower S~,903.Sl 103.
104 P,woffto9Jnkof /mitdcn S◄?,582.~~ ~104.
10S. ~•yoff,o BSVACo:npo,s S91,094.91 405.
Atlfu.s:tmcntsforHetr.sruiidbyltllcr in :1dv:rntc htlj1tsrmcntsfo1·ir:r.u. pn!d by tclkr In tdYnnc-c
l 06. City property1:,.,;cs 106. Cityproperty~'IX~
107. County propc1tyt.1xe.s 407. Cour.typro..,cnyto_.'(cs
i OS.Assessment
T~.xcs 40S. Amtimcnr Trucc.s
109. Schnolrucp<«Ytlll(es 409. SchoolpropertytlUtcs
ll 0. OU,crt•~c.s 410. Oihcr 1ro.'.C$
I 11. 011:crt::.,;c.$ 411. OlltcrLixos
I 12. 412.
1n. 413.
I i4. 4M.
I i5 lit 5,
116. •116.
120. Cross An,ouut Om: 1'1·0111Oon:>w:r S!•l7.S80.R7 Du~re ScUcc-
1110, C1,ou ..\.tno1111I
200. AmounrsPoid UyOrin nctrolf or0orrowe:· 500. Rttluctions in Amou:d Due to S::lltr
20!. Ocpos±torccrn:s1
n1oocy 501. E«c.ss d:smil (seelns1nic,lons)
202.. P,inci;u1l
:tMcunloi acw loan{s) SJ36,000.CO 502. Sct1fcmon1eh11<&cs10,oiler (lin: 1~00)
203. Exi>ling!o•u(s):ok.., subjcclto 503. fa!S1inglo•n(s)rnktl1subjeei10 ✓

204. 504. Pnyol!of flrs1:nong•gc!ooa
105. SOS,Poyntror oceonomonc•t• lnao
206. 506.
207. 507.
205 50!.
20?. 50?.
Adjus~mcnufot Items~1111:li<lby seHi:, AdjuilmcntJ fer Hemsun11nldl>yJcilcr
2 !O. City tJ:OFe:iy
t11xes 510. Cityproperry""'"'
21 J. Cou111y pr:pc:,ytox.e.s 511. Caunlyr,:·opcrty
tl'.Xts
I
211. ,mcssm:n1toxc.s I 512. Assossn:c:it'f3~es
2 ll. Sehcol!'ftlP•lt\'taxes S 13. S,hool prop:rr1 rrn<c.s
21-1.Ot>.=r1:u:cs 5 M. O1hct1ir,cs
215. Otbr true"' 515. O1hertn:.:t.S
216. 516.
f 217. 517

.,...
21~. 51l
219. SI?.
220.Tout! P:JldUvJf.orOo:-row:r S336.00C.00 520. Tot:11nct111c1l:ut
,\monn1 !)ucScl!cr
300. Cr:shAt Sc1ttcme1,tf.'tom/'rn
Uorrowc1• liOO.Cnsl1Al Sc:1tcme1HTc/P'r~rn ScllCJ" ~

lOl. Oro-ts/u;i::mnt,lue from b~:o\~'Cr(lbc: 120) St ➔7,5ll0.67 601.Gro~,Amounidue to seller(line~20)
3M. Less :unct:ntspnid by/for bouvw~t (h,~c 220) SJJu,000.00 602 Leu ~ducl!onsin ::nnt.Cue:seller(linoS'20)
303. Cns,!11"nDnrn:,·,ver StSS.-11?.tJ Ml. C~sh S~llcr
Brntti.;n(o: tht!l:
Tr..cPnl,!icRL'fll'!tliog isa,imrilci.lnt 3 Snih utc:.perre5p01ueforc::r.11::tiua,
collcttio:1of inl0m1:Hin,1 n:vicwini;.nndrt(lott
o•~ynet .::,ll«t this iufmnitiun, Md yi;11
r.!n:retl;U1isdtscl~ureis mrJ1rlo:ory.
POC(U)-P:lid
nronnr<eq11ircll ~1~ lilrm.""(' ~~ I( displO)~o <11,rcn!I~
(0 rom11lc~<
Thi5 i~d:>i~1cd10r,rovil1elhc p:uuc.s
vnlid0MB controlnnmbtr.l
to a Rf.:.l>i\coveted lrnr~u::tiO-"'l
with info:mntlondutittt theS1
b)'Sell~. J'OC{L)- i'nldOut,ld~of Clmfng
Outiid::"fClo~tnc by Scrmw:r. l'OC (S}- Pni..t Out.lid, urc1u.si115
\)} 8
I

?revjous editionsnrc obso:C:c MUIH
I'll, No. ll.>U'&t.lff~OlJ
L. ScnlcmcnlCb11rgcs
?GO.Tot11Int1tl&talc Brakcl'Pees 'PddFron1
Olvitic11of'Ccmmiuion (line700)os tollows: Sella's
701. 10 Fundsal
702. IC Sdtlcmcnt
703.
704.Thefotlo\rinfl
parties,pcisons.firmsOJ !O
7OS.corpomr!ans
h4vencelvcdIIpottioAOt ED
70S.lhcreeleauccammtsslon shown llbovc. to

800. l!tms P11ynblc
haConnectionwill,Lo11a
101.Ourorimnation
..i..-a I
802. Ycurcredit or ch- '""'nbl rcr IJ!csne9£.rll~.
ao>.Youradjustedongmatlcncharges co ComponDllak
. .. _ ... -.. -
SJ.19&.'ISI rrmmQFEOll

(ftumOFJ!A) 53,195,'15
SIM.ApprnlmlPee Suvl, tu. Ltd.
10 Southwcsl Fln11nd1tl •oc<D> (R'onaQPJ! #l)
SUS.Gt
sos.Cn:cli1report EO £4alraxafor131111cSolullo1
Is POCIII)
.,,;_ QmmGFBOJ)
806. TIIUctVICC co CorcLqlc (ttoffiOPBl3) S105.GO
807. Floodccrtifimioa t0 CcrcLo11lc
PloodSent= (OumG.PBl3) Sll.SO
SOB.Oocumc:id PrcpAndioo
FeecoPolunslcy
&
g..;,.., P.C.~ nn son "'
,ft

!JOO.
llemrlb!l'luJftdbYLcnduTo DePlaidInAdnncc
001. Dellylnlcrcs&
ohiiracshm 6/lVZOll lo Ci/l/l013@ S33.37/day (CtomOF&llO) $333.10
902. Mftffaft"C JMtlntllCII Premium
fat fflllllths to rrtomCJPB13\ I
rnumOPJ!,m I
UlCO.ncse.rvcs DepositedWith Lender
1001.lititinlDepositrcr youraciow occ:cunt (&omGFBD9}
Hcmcownen
11102. insurw:c morubs~~ p~monllt
1001Mcrlgcgeinsurance months,1 p::rmaalh
1004.CilYpn,pcrtyram months,I m=rmonlb
1005.CountyPtOperty tmccs ~
monahsC P :rmonlb
IC06.AsscssmtnlTmtcs monlhs@ Plrnwnth
ICD7.Schocl pfflllffllltoxcs monlhs~ p:rmcath
mon1bs@ l'ltrn=tlh
moruhsml
1010.O!hctcaxe.s montbs@
IOII. AA&teaalA
AdJuilmcnt

1101.TIilesesvlces
Md lendcr'llitleinsurance IO AUcnlancc TIileCommDY (ftmnOFBf.t) 13,127.56
l 101.Scul=cm orclcsfngrec to AUcclnncc narcComruII)' $175.GG
l 103.Ch'fflCl's
Clllclnsul'IIIICC lO AUe1lc111ccTlllc
Coran111y
l 104.Lelldcts1,t!cinsunmcc co Allc.11.l11uec
'1111c
Oimn111v 52,181.110
l lOS.LcndctsliUc~C¥ limitS S33&JM)O.OOJS2,88G.60
1106.0wnn tltlepoli;ytlmil$
1107.Apl'I porCionoftbe
IO!Altlllc lnsllfflnccpmniunt 10 Allcg(AQCC'lllcCamn:any
port=nof!ht ~ titlelns1111111cc
1108.Undl:nvrites's J)lefflium10 TitleRtsouus G1111r2nly SOUi)
AJlcgllmccTitleCompany•
1109.StileofTexasPolicyOucrcnly
Fee 10 Gm1r1mcv tree SZ.OO(hmCIPHt)

1110. Swc oncxasPolleyOuanmty
Pea
nucCorup1111y.
to A1lcgl11nce (&o111ClfEa5}
Gu2r1111ivFee
1111.c-Iword!ngFee lo Allcgl11acc
TIile Cc111p1111r S4.00(6m!ICRl4)
(MTP& BIN
1112. NolycLdudpAyiil,la to AUegloaccTIUc Ccmpan]' ss.ao
1113.Taxddcllon(MTP & BINDER.
ONL to Allcgl.oncc
TIileCompany S20.CO
1114. Envlrcnmcnllll
ProiccthlnUcn 10 Atlcgbmcc nneCompauy $25.00
111S. TU)Res.Gmtossomc:nt to Atlrglnntc1'JtlcCcm(IDAf SlO!l.10
1116.T42 Endo,scmcnl U1 Allqin11a:Tille CcmpAl1l' n1uo
1117.T42.l Endo~ 10 Al1c£1n11"TIiie: Compziny
ms. i-= Ccdificm.c 10 AUcglnucc
TIiieCompnay SS'1J5
('4-amOf&IH}

Govunme1lfRccordlagand Tra0ffcr C11111cs
1:ZOD.
1101.Oovcmmenr
reconUsm
cbt1mes Ol=OPBll'7) Jt28.CO
1202. MOrt8llaCS92.00 'nl e C11mp11t1)'
lo M1egui11c11

1203.Tnnisli:r1DXOS (ll'on,GPl!tl8)
1204.CityfQ)\1111)'
llllC/111Unps

1206.Home~il)' Affidavil 10 Allce.l11acc
Tille CG1n1111v $36,00(ftom Gf'Bl7)

1300.AddUlt1n11l
Sctcfcmcnlct111rgcs
1301.Rcciulicdsmlccs youcaasltcp i« (rromOPI!06)

J,100.Tot11I on lhtcs103.Sccclou
Scttlemca,Cbarnesce111er SccllonIC
J and 5111. I S6.90351I
Ii)' Bono-. l'OC(S)- PaidOur.fd •otOosba by Sella. l'OCCL)- hid o-ido
PCC(D)- PaidOv11idcof'Cloti111: olCIA;ln& 117
l.Gadcr,

Previous editions aTCobsolete Pagc2iof4 HUD•l
fileNa. Jllll~ll
CnmflflrilouorCood J7aitllEstlntnte(GF£) 1111dHUD-IClmrgcs GoodlfnilhEsrhnntc HUD-1
Charges
Tl1n1 hu:re.,sc
C:11111ot f HUD-ILite Nmnbcr
Ournriginntion
c!s:11U: '8 I SJ,196.75 $3,196.75
Your\:fcditor charge{polnlS)for the specificrule cltosen 82 so.oo so.oo
Yourodjustedoriginationcharges 'll 3 SJ,196.7S n.19G.1S
·rrnnsr~lm:C$ 'II 03 so.no S0.00

Ch:irgu Thnl in Torn I C11nnor
hm·ensc MoreTJ1n11
fU¾ COOII
Fuilf1Escbn11Ce IiUD-1
Oovcmmcnt
recording
churges 20! sm.oo 5128.00
AppmisnlFee
Creditreport °"
OS
S425,00
$16.00
$425.00
$16,00
T:ixser\licc 06 SJOS.00 SJOS.00
Floodccrtincntion 1: 07 S12.S0 S12.50

lncL·cru;c
To1al
HU •I Chnme.q
bclwccnGF£ 1121d I S670.50
Sl&.00
I
Di.'
$6'!1650
2.3!)1/,. I
Ctsurt?CS ·rbnl C:1nCbtUlltC CoodF:iithEstimnlc HOO-I
lniti:ildepositroryourC$Crcw nccount 1 1001 SO.OD SO.Oil
DailyinlcrcStcl1nf'3CS ~ 901 SJJ,37/dll1, $333,70 S333.70
Ucmcowncr':s
insur1111cc l 903 so.oo SO.DO
Titlcscrvlccs
andlem!cr's
1l1h:
insurnncc 11101 SJ,704.00 S3,Jl7.S6

Loan Terms
Youriuilial1011nnmounlIs 036,000.00

Your101111
termis ~Oyenrs

Vcmri,tiliulin1crcstr:ttcb 1.625%

Yonriniliolinon1hly
Gmountowedforprlneipol,intcresLn.-tdanyniorigagc: •1.S32.33includes
instlr3nClll$ El Mncipnl
Bl ln~rcst
:J Mortnnaclnsumnce
Cuny\)11t in~l r111c
riSll? BlNo.a Yes,it CM rise10 11maxJmum or 0%.Theflnstclumgc willbeou
Uldcanchangengoinevery oner. T:ve,ychnngedntc.ynurb11Ctc$1 r.uecan
ncrcu,eor decreaseby 0%.Overthe lireof tile loan.yourln1i:n::si
l'lltc ls
unrant=dro,,,._ver
be lo\vertlum0%or hfoherrhnn tlo/o..
livenii'you mnkcp:iymculson lime.can yout lonn bnlnncerisc'l Bl No.O Ye$,it Ganrf:si: to A mmdmuinof SO.CO
l!vcnffyoumsf;cpaymentsen time,canyourmonthly ElNo.□ Ycs, the firstin'"nsc e&1 ba on andIllemOlllhly
amountowed
:imountl>\\'Cdru~nrincinnl i,11
..~--:,t.ndnuirtn....e imurnnccrl~o? ~n riseto SO.CO it cuneverrfa to Is S0.00
TI11:11111Ximu111

Deesyour lonnhavenprepu)'mcnl
pcmllcy? In No.0 v~. yourmaximumpn:pnyment is $0,00
pcn11!ty
Deesvcurloanhaven balloonMun1ent? ra Nn.□ YCL vouhavea b111loon
Mvmcnt or SO00duoInOveerson

monthlyamO!!?lt
1°01111 owedh1clufli11g
escrownccountpny1ni:111s ~ Youdo noLbnvca monthlyescrowpaymentfor items.suchas property
undlulmcowner's
1111c:s wumn1.:e.
Youmustpay theseltcmSdlrcclly
-oumlr.
J Yon hnvcan additionalmcnthlycsa-ow))l\ymcnt or
l'C$Ulls
1111 in ti tot:ilinitialmonthlyamountowedof$1,53l.33. This
11Clud~principal.inlen$1,nny 1110rt8,ngc
insurance1111d
anyitemschecked
clow:

' J Properlylll."!.C:S O Homeowner'!
losuranec
!J Floodin:suruncc □
!] 0
du: Si:ulcmentChmgcsend LoanTen ~ listed on this fonn,tllCGSCconmctyourlender.
Note: l(you lm-n:nnyquestionsnbo11t

Previouseditionsnreobsolete Page 3 ~r,1 HUD-I
FileNo.1332220-ALND

I havecarclblly
rcvlc1YCd
lhcHUD-ISCfllcment end lo Illebestofmy.lcaa
Sl!Uemenl ~edgeandbelier,Itis Acmc11Ddm:cmu1eallllcmall of1111
r=:fpll Ind
madeen myaccountor bymeillthisIIW4Ction.J fimhtrcertify l haveICCCIYCd
disbwseml:nJs 4 completed ccpyof pages••2 andl o!!lt!sHUD-IScu1=cffl
Sloteme11L

g}//
~
Sern.EMBNTAOENTCERTIFICATION
TheHIJO.lSctllcmcnt whichl luwc~ isa uuc=cl~e
Sl:\lctn=t
ccccmuord!is b'lms1!dion.I &o.vo
cmiscdihii fbndr lo bedJsZnzn:cd
In
accordaftcc
wittaChisstaICmcnL

Sctllemcnt
Asant
WAmlng:h It a crimeat kMwingly make&lsc11111cmcntsto CheUalicd
SU!tcsen (biser anyod1cnEmitar
ronn. Pcnllllics
uponccnvlctlcn ccn
Pctdctoilssec:TIile18U.S.Cocl.c
includeIIfineand fmpris011mcnt Sc:crion
100l and Sc:clianl 01O.

Previouscdnionsarc obsolete Pagc4 f4 HUD-I
FiloNo.W~IJ
u ....L v-:i:vn r.1. vu u, v, t..Vt..-: v, .t..v, .c...1. .r-n 1..u.1. rnui....
TYLER FARRIS CPK49966) COMPANY:

CUSTOMERACCOUNTACTIVITY STATEMENT DATE 06/06/24
PAGE 1

DWIGHTL HILL
MARIBEL L HlLL LOA.~NUMBER:1210015809
4647 ELSBY AVE REQ BY GUO
DALLASTX 75209

IF YOU HAVEQUESTIONSABOUTTHIS STATEMENT,
PLEASE CALL PNC'S CUSTOMERSERVICE AT
1-800-822-5626. VISIT PNC.COMTO ACCESS
ACCOUNTINFORMATION.
*******************************************************************************
-------------------------- CURRENTACCOUNTINFORMATION------------------------
DATE TOTAL PRINCIPAL LOAN CURRENT
PAYMENT PAYMENT & INTEREST INTEREST PRINCIPAL ESCROW
DUE AMOUNT PAYMENT Rt~TE BALANCE BALANCE
07-01-24 1,532.33 1,532.33 3.62500 252,245.55 0.00
2ND MORTGAGE: 0.00 0.00000 0.00
********************~**********************************************************
ACTIVITY FOR PERIOD 05/17/13 - 06/05/24
PROCESS DUE TRANSACTION TRANSACTION EFFECTIVE DATE
DATE DATE CODE DESCRIPTION OF TRANSACTION
TRANSACTION PRIN. PAID/ ESCROWPAID/ ------------OTHER--------·-----
AMOUNT BALANCE INTEREST BALANCE AMOONT CODE/DESCRIPTION
06-03-24 06-24 171 PAYMENT 06-01-24
1,532.33 768.02 7 64. 31 0.00
252,245.55 NEWPRINCIPAL/ESCROWBALANCES
05-01-24 05-24 171 PAYMENT
1,532.33 765~71 766.62 0.00
253, 013.s-, NEWPRINCIPAL/ESCROWBALANCES
04-01-24 171 PAYMENT
04-24
1,532.33 763. 40 768.93 0.00
253,779.28 NEWPRINCIPAL/ESCROW BALANCES
03-01-24 03-24 171 PAYMENT
1,532.33 761.10 771.23 0.00
254,542.68 NEWPRINCIPAL/ESCROWBALANCES
02-01-24 02-24 171 PAYMENT
1,532.33 758.81 773.52 0.00
255,303.78 NEWPRINCIPAL/ESCROWBALANCES
01-02-24 01-24 171 PAYMENT 01-01-24
1,532.33 756.52 775.81 0.00
256,062.59 NEW PRINCIPAL/ESCROW BALANCES

DLH-009256
.i.:.1· "1':tVfl-r.&. vu u, v, ~v,-z "'. ,v, ,.1. rr, ,:.uJ. rnuc. "' vv.J a:a.A .., 0 .._ v o.£
TYLER·FARRIS<PK49968) COMPANY:

CUSTOMERACCOUNTACTIVITY STATEMENT DATE 06/06/24
REQ BY GUO PAGE 2

DWIGHTL HILL
LOANNUMBER:1210015809
ACTIVITY FOR PERIOD 05/17/13 - 06/05/24
PROCESS DUE TRANSACTION TRANSACTION EFFECTIVE DATE
DATE DATE CODE DESCRIPTION OF TRANSACTION
TRANSACTION PRIN. PAID/ ESCROWPAID/ ------------OTHER-------------
AMOUNT BALANCE INTEREST BALANCE AMOUNTCODE/DESCRIPTION
12-01-23 12-23 171 PAYMENT
1,532.33 754.24 778.09 0.00
256,819.11 NEWPRINCIPAL/ESCROW
BALANCES
11-01-23 11-23 171 PAYMENT
1,532.33 751.97 780.36 0.00
257,573.35 NEWPRINCIPAL/ESCROWBALANCES
10-02-23 10-23 171 PAYMENT 10-01-23
1,532.33 749.71 782.62 0.00
258,325.32 NEWPRINCIPAL/ESCROW BALANCES
09-01-23 09-23 171 PAYMENT
1,532.33 747.45 784.88 0.00
259,075.03 NEW PRINCIPAL/ESCROW BALANCES
08-01-23 08-23 171 PAYMENT
1,532.33 745.20 787.13 0.00
259,822.48 NEWPRINCIPAL/ESCROW
BALANCES
07-03-23 07-23 171 PAYMENT 01-01-23
1,532.33 742.95 789.38 0 ..00
260,567.68 NEW PRINCIPAL/ESCROWBALANCES
06-01-23 06-23 171 PAYMENT
1,532.33 740.72 791.61 0.00
261,310.63 NEW PRINCIPAL/ESCROW BALANCES
05-01~23 05-23 171 PAYMENT
1,532.33 738.49 793.84 o.oo
262,051.35 NEWPRINCIPAL/ESCROW
BALANCES
04-03-23 04-23 171 PAYMENT 04-01-23
1,532.33 736.26 796.07 0.00
262,789.84 NEWPRINCIPAL/ESCROW BALANCES
03-01-23 03-23 lil PAYMENT
1,532.33 ,34.04 798.29 0.00
263,526 ..10 NEW PRINCIPAL/ESCROW BALANCES
02-01-23 02-23 171 PAYMENT
1,532.33 731.83 800.50 0.00
264,260.14 NEWPRINCIPAL/ESCROW BALANCES
01-03-23 01-23 171 PAYMENT 01-01-23
1,532.33 729.63 802.70 o.oo
264,991.97 NEW PRINCIPAL/ESCROW BALANCES

DLH-009257
Cr' .:)'tVW-.t'.L VU U/ U/ L.VL."% t.J • L.V • tC...J. ra·.& C.JJ .l rnuL:.
TYLER..-FARRIS
<PK49966) COMPANY:

CUSTOMERACCOUNTACTIVITY STATEMENT DATE 06/06/24
REQ BY GOO PAGE 3

DWIGHTL HILL
LOAN NUMBER! 1210015809
ACTIVITY FOR PERIOD 05/17/13 - 06/05/24
PROCESS DUE TRANSACTION TRANSACTION EFFECTIVE DATE
DATE DATE CODE DESCRIPTION OF TRANSACTION
TRANSACTIONPRIN. PAID/ ESCROWPAID/ ------------OTHER-------------
AMOUNT BALANCE INTEREST BALANCE AMOUNTCODE/DESCRIPTION
12-01-22 12-22 171 PAYMENT
1,532.33 727.43 804.90 o.oo
265,721.60 NEWPRINCIPAL/ESCROWBALANCES
11-01-22 11-22 171 PAYMENT
1,532.33 725.24 807.09 0.00
266,449.03 NEWPRINCIPAL/ESCROW BALANCES
10-03-22 10-22 171 PAYMENT 10-01-22
1,532.33 723.06 809.27 o.oo
267,174.27 NEWPRINCIPAL/ESCROW BALANCES
09-01-22 09-22 171 PAYMENT
1,532.33 720.88 811.45 0 ..00
267,897 ..33 NEWPRINCIPAL/ESCROWBALANCES
08-01-22 08-22 171 PAYMENT
1,532.33 718.71 813.62 o.oo
268,618.21 NEWPRINCIPAL/ESCROW
BALANCES
07-01-22 07-22 171 PAYMENT
1,532.33 716.54 815.79 0.00
269,336.92 NEWPRINCIPAL/ESCROW BALANCES
06-01-22 06-22 171 PAYMENT
1,532.33 714.39 817.94 0.00
270,053.46 NEW PRINCIPAL/ESCROW BALANCES
05-02-22 05-22 171 PAYMENT 05-01-22
1,532.33 712.23 820.10 0.00
270,767.85 NEW PRINCIPAL/ESCROW BALANCES
04-01-22 04-22 171 PAYMENT
1,532.33 710.09 822.24 o.oo
271,480.08 NEW PRINCIPAL/ESCROW BALANCES
03-01-22 03-22 171 PAYMENT
1,532.33 707.95 824.38 0.00
272,190.17 NEW PRINCIPAL/ESCROW BALANCES
02-01-22 02-22 111 PAYMENT
1,532.33 705.82 826.51 0.00
272,898.12 NEW PRINCIPAL/ESCROW BALANCES
01-03-22 01-22 171 PAYMENT 01-01-22
1,532.33 703.69 828.64 0.00
273,603.94 NEW PRINCIPAL/ESCROW BALANCES

DLH-009258
,._.,.., ,a.vn .a. .a...,,.. _, u, "-V"-~ tJ • "V, ~.L. t"a•.a .L:.L./.L l"'l"lU&.:. ,J/ VV..J rd.A OC:,.l V~.L
:TYLERFARRIS CPK49966) COMPANY:

CUSTOMER
ACCOUNT
ACTIVITY STATEMENT DATE 06/06/24
REQ BY GUO PAGE 4

DWIGHTL HILL
LOANNUMBER:1210015809
ACTIVITY FOR PERIOD 05/17/13 - 06/05/24
PROCESS DUE TRANSACTION TRANSACTION EFFECTIVE DATE
DATE DATE CODE DESCRIPTION OF TRANSACTION
TRANSACTIONPRIN. PAID/ ESCROWPAID/ ------------OTHER-------------
AMOUNT BALANCE INTEREST BALANCE AMOUNTCODE/DESCRIPTION
12-01-21 12-21 171 PAYMENT
1,532.33 701.57 830.76 o.oo
274,307.63 NEWPRINCIPAL/ESCROW
BALANCES
11-01-21 11-21 171 PAYMENT
1,532.33 699.46 832.87 0.00
275,009.20 NEWPRINCIPAL/ESCROW
BALANCES
10-08-21 10-21 171 PAYMENT
1,532.33 697.35 834.98 0.00
275,708.66 NEWPRINCIPAL/ESCROW
BALANCES
10-01-21 10-21 170 BEGINNINGBALANCES(ESCROW,INTEREST, ETC.)
13,790.97 6,182.43 7,608.54 0.00
276,406.01 NEWPRINCIPAL/ESCROW
BALANCES

DLH-009259
I
Uniform ResidentialL'i'
Jan Application 130'1!)1101

P;:ortgago Number
Le:;1.tl:.:rC.au
Applied for:
timcunt Amcr!it!ll:n

sJJG. 000. 00
IT)'Jlo:
~RM (typ6};

Lcg::il On;rl~ ot Sub:r....tP,ap:rt'/ (•lt~ch d:n~!ptl;,:, ll' lfOCUUty)
YurDuf!t
t.o: 12. Block B/ssao, Limiocd Place

Pwrouort.oao D Putc:huc C:m:tn.u:Uon Otfli::r(cl'p,I 11~ Pro;ii:rtyw;Ubo:

-::---.-.-.,,-=W~.:.;R.:.;'";;;'".:.;'";;;'•;:__....,,,==..:c..:""c:.:'..:.'"':..:'c:.lic.:.;•:..:·"..:";...~..:•..,"'.,.."c..'
--------t---------'-'=x=·"-"~"':""t?,.,,.,,ne"- .. -"O='-':"':=,,,~de,n
.."r:1;',.,,.'---"o_"'lr.~
Complototh!!: lino if consln.ia1iot1
Yt-J.rUlt
Acq:.i'.rtd
or con.'itn:clion-permrmentlean.
Orfs;!na.tCast Arncunl l:ilcalno U~1n I [u)C~atctlm?J'GlfC.ffl<!t'llt.

I S I
Comp!a!ethis line ii tnis Is a refinancelasn.
Yc:zr Ot19ln,1I
Co~\ Arnour.t£d.slir.g Uen; ruq;01c o~Rd ln.:.r~ti Oc;alb<>L-r.provtmcnl:S Orn:.t!o 011:1100,m.:iao
At(jwITTlf

--::c:':19~9;;;':-::::;o,.':"C'.si':o':-.
oi'io'-'::':-:.i'oi-o
_____
1it:ew:!lb.th~ld lnwh:>1111.i,11{,)
,._._,.i~s. ooo. oo Icanh-cut ther
Ccut:S
w.,-MortriwMUITil!owUI l:::ehcl::I t;s11to~llfbo ho!J kl:

"'DWI=G'"H""T=L=HI,..L_L=&'""""H'"M=!!l.,,l!L="L".c:-:-H-:-,I,:,Ll,:,=========------i---'-=-~_.,._x_-r_:.._n_a_e_l'C_R_T
_______ --j ~fODS!,,,pt•
cnu9es, .::m.1.
so11,c• Cf Down 1•ayrnoo1,.Scllli:mc1.-u 1
::r s~corC:l~!e fl:u1n:ll\O (Op5thl D lc.uchoto
Chc:ckir.g/Saving:; , ..~~pn11~11d.1~J

Borrower Ill. BORROWERINFCilRMATION Cc-Borro\'/Or
Cctre-"w' N1n-.olltu:lut:cJr. otSt,ft1pplk~lc) Co• tn:iwcto N&molln®doJr.or Sr.rrapplJ:.Jblo}
DW!CH'i' L HILL M R.I9EL L. HI LL
S~c.l~ St:uri!t N..:mber Horne Phe."lti(~J. tre:a cc<!ol OCO(i/J,ilCOMYYV! DOB(/,ll.t/001\'YVY) Yrf..School
-'Hi0-25.-l52J ('-14} 4'78-31S0 10/0l/1!1'4 lG (21t) .::;10-31S0 11/08/1969 lG

,: 6°1? ELSS\' AV£ 4 Gi BLSEY /WE
DAt.U'iS, 't'X 7S:!0!1 D ~S. TX 75209

If rosiaL,g nl prcsont eddross lorla.ss lhnn twc ycor:s,complete !he following:
form,r Add=• (&uc,~ dt;. :,,:,. %JP) Ocwa □••" 110.Vn. ~

~ Sortcwer IV. EMPLOYMENTINFORM,\TICN Co-Borrower
y,s, c:1lhls Job Ha:n;• A:fdr.iu of l;mployar [}Jsd!Emsllcvcd Yrs. en t:tJ•Joh

'O~fIO!t'l.' Htt.:.. ItJSUR.."\UCC l'.G!?NCY lZ.:C ~ Sycs 0n-.oa OW HT Ht LL INSUWJCS AGENCY ll!C. l:?yr:1 0mo::1
Y;s. enp!oyt:: 4 2 a; ti LOV£R.S LN' Y(f..c:r.i;icy~
si~6 II L-OVERSLM b!til1Unoo: 11"111111 Qn:of
llAl,r.AS. TX 7520, ~,l{/pfofculon D uAS# TX '15209 worklprcfuQan
2SyrG Olo'IOD l~~l'.l Omoa

Pc~UlorJTJlk/Typc cf Buslnc.;s eur.tr.ua PhUM (Ir.cl. :rait tod111J
PAf::SXDet..:T {211} 727· 575.'1 !2l•l 352.740,i
INStruN ;. INS"JN'1MC'R .
If omployedin curronrpa.sil/onto:Foss!hon Mo yoars orlf c111Ten(ly
omplorodin mor tho11
one no~liion. completethe fol/c,•nr.:
UAntca.,,d;reu afE.r.lp!o,cr Sol! Empl<'y:,d Datu (frcm-to) H.un & Adc!:u::s~rfrr:~tc,·•= Ds•U' f~:iyoa

OAIU 1rrom•IO) N.tffl t. Addrou Cf EmrJoyet Otlos (CrotrWa)
St\lE:npk>ycd

DLH-009272
V. MON I HLY INCOME AND COMBINED OUSING EXPENSE INFORMATION
utOSI 9ottO'f,'¢t
t.~n:N IMO.on.

7,592.)7 7,992.375 15 !J84. ;1 noi.:

l, 500. 00 l 1,532.JJ
Ber..ao, ~00.00
116 .oe
750 .00 716. 91

~~~e'I Aa•cct:~C..-•
r~fl~
~ •"t-,-,_
Tcftl 7,992.:ns l 5 !)a-1. 7,q Tol~I 2,750.00$
.. Scl!Empfoyod Borrowcr(:s) r:,oy uo rcqutrcU to provide \lddlllonol documoni lfoo such n:s tox returns and financial utotcmonts.
Describe Otho, Income Nolica: Allmony, ch lid support, er scparat rr.alntenance Income need not be revealed If the Borrower
(BJor Co-Borrowcr{C) does not ell ose !o havo It considered forrepaylng this loan.
8/C Monihly Amour,t

VI.ASSETSAN
nu::sz~.tcr.dan'J•~~s~r~sw~stl'.afbtc:.mptaadicmCvt,ybotlmv:~cr..sw- ..tat, ~-D~ntltrtUci).leU...i~uuonlb•tryfdC'"Ad,:stlAIU...Sit::.t.:u.~Junbe
::~~tr,~c:z~'t! ..•~-~~~ ~~~! ~~~~i;:~~;~:c_:Utt at• t tf Ott&Co-Q:,t::11,trc, socbJ,"1\JI.Uar.'.;::.t.dtJ:;u •ncn-~~r,IQlll•ot .lllct pets:.n,.

Cc,nplt.lcd (fil Jolnlly D Uol J.i,IAuy
~=,:tet IAa,)t~I
V4!V~

UcrJt:t-JP,ymeAt£
L ABILITIES lbntln ltft 10Pay

.,...,--,----,-----,---,---....J.-----------i"'n11 ar.U&:it:,.en ol Cffl?,lll'/
LJ.Uu~.M,o ~.:J :..a~J: ~: cc:.,.,11
-,---,----,-,-,-,---,,-.,,-,--,----------!sec Co:'\t.inuat o.~ Sheet for
:t:r.-.a ~ Kd:C.n cf 9~-,i.,. S&L, 01 Cr,ttt Ul\'on
COJ,'.PASS
Schedule ot L a.l>1llties

Uar.lO ar.d .:.d~tO" of ClmP11V

5,795. 6-\
N:ur.o.irtd;u:ld,us c! S.inll:.StL or t,"21 Uo1cn

A«t. no,
u~, end :.ddrtui• or om~"V S Po1m•nlJMontlt•

A,Cl:!.:IC.

t::uu ~,:1J.d:rcn C:~ Sll. or Cre(lt Ur.Ion

I.ca.no.
Jl1n• SJ\d :i4dltl&S Gr O~p.li\)' s Poym,nLl-.:o, ti\s

ric:t.nt\.
:t:ma:ind 2d.t1c.i&:al D~r.Jr,S4L, or Croif.t Un1on

.:.cct.i,o,
r4ame-onll •dd;n, of ~y S P.1)111'\lntJUOJ\thS

Sic tin & Cand.c.(Ci:mp.11')'n.,r:n'riurr.t:.c-,
~1.10::rl.ptkml

I.if~ tn~ut.uu:1 no~c.1U1v1\1• 0 .00

Subtotal L!quld Asset,; S,79S.64

l, '1)~, 000. O0~-----+---------i
Acc.:.::c.
S Prµncntl~tf'Jns

>:11-wouuot bualncu(o,J ovm:u
0 .00
{alt~~ f.t1a.,c.ll.l£t.1.1a,r-.o:,I)

E11r,1nu t htld:cauc, union (luu, clc.J
Jon-rtote11ccJ

Total r.tonthly Pa mcnts
N9t'Wor\l/·• .- ; To1alUabllitioo b. ~27,811.Bl
- ·• ____
Total AssclS a.
...
l,,Q40.i95.G( nmih°usi) .'••
Pc.g12cd
1,212,973.Sl
1=l 71:5 (fcV. UCf)

}~~';i!~f~~~i7,itf,~~~j 0

c ,~rlauG ~,nsnc:ul Colutio.,,~. :~c.
J . •
I
I ll019ll01
·, • I , • VI.ASSETS
ANDLU\BILITIES
cont.
Schedule of Real Estoto C,•mcd (If addi!l<lnalproportiot are ownod. use ccnllnuobon •hee!.)
P1<1;err;Admu \tn!tr S tr Soia PS JIJ)tl\itino -{J, Typt el Prntnl A til"l GI L1s:.:r.1nco,
Ucr1o•ao J.lclt\lt~a..,c.o. Net
ot n r rcrJel bc!ng i.ettt to, rnccmoJ v
1-.1.lo ?toptn Mlrl-le: Vn!uo J-.'artggn '4. Lions Rrni!J~ri:ome Pi:.ym!r-.!$ T•xt~ t Ul&c. Acnt1.Itnieomo
s s s s s

See Continuw.tion Sheet fo:.·
s s
Schedule of Real Estate o,med iolals
99.071.Sl 1,1lS,0Co.t3 0.00 3,l9J.OO 1.122.l~ 0.00
Llstany additlonal names under\'Jhlch credit hac 1,rovlotmly b.lon rocoiv(ld nn lndi .....
•· !• •'pproprl•lo
" , rn amc(•)
crod·to ~ (s) :
• and account numuer
Alternate Nama Creditor Nnme Account Num~er

Vil!. DECLARATIONS
ff you an wor"Vcs" to any questtons a lhrouch f1 DllttOW'C( G:t-Senv.v-::r
b. Altera!ions. l'llpro.,ements. repoitS ploaso u o continu:,tion shaet for <!ixpla.nation. Vta H11 Vu ,:o
c. lllnd (If acquired separately) a. Au, lhet 1/fJ ~~~"'4no fWJtnCfl'l,1tJ!!IUI ),'CU? DGJDGJ
d. Refinance[Inc!. debts lo be ooid ol:) l40,Gi'7.J.6 b. ibVO,)~ fflflC:t:1:.rodbll~IW.tl"l1'U'i~J:a,17)'otn.7
DGJDw
c. Esllmatcd prepaid Items 3J3. 70 <: ttovoyc •h'4p:q,1nyforc@,o!il.-ptn"OJ gtttn :itle«di:e,::
fnDou cd•n!ho.Jtul7~m7
DwDGJ
I. E>tlmele<lclosing C0515 7,010.81

N• you U.6. ditcn7

~ "10}:)tl pc.~ ....Af:!nU.lt'f:,\aCII\?
m. Loon amount 1. Oo yv11 11,nd 10 oc.euftytho propc.n••as your s:rlmaryre~tdcnce?
(exclude
PMl,MIP,Fcnding Fee financed) JJ6.000.00 lf"'VH,"' m;l.\14q4:t0,toonmb.:I\M,

n. PM!, MIP. Funding Fee financed 000D
336,000.00 SIi Sil
o. Loan amount (add m & n)
SP SP
- .l80, 119. ll

l.t'"f9?\;9':;iet".er'l Ela\ 0: L'Utcn:'eri!Q.~l'lrt~ It~~ ¥,,'\fO-iC:et oJL~e~ lt s~etrs.
~ck,'".C,.\teen&~ tui:co,~c.r: ~ MsJcn.,. fr\J'/ w:nt, ot ttn4l{ty 'tt.."'I'/r'J(.(ffl.1t.10o
W'l~:S U'Ill'Ja ~bn Ct
ZSI.De1 ,,,...,if".,Cl"IU~crd~..:t,c:oi'-,a1oth:c \.o=f\ :e:u, 1 1cg:mn:abu1L·..:u,s:~~d'.too.)hln'J~rtl. noa ,oc,::.1111:1"11:flt\:ats
~loncrn cc.1u.--r:.:.r1~-&IQ:.,otncy

Oate

TI1efc!lowillg informollon Is requastedby the Federal Government for cartnln IYJl"~Of leano rolnled lo Gdwelling in order to monitor the lande(s compliance
with equal c;edil opportunity,lalr housing and name mar.gaged1sciosurelaws.Yo are noi requiredlo iuroish !his lnfomrnlion, but ara encouraged lo do so.
Tho law provides that a lender may noi disc1imln~leeither on th~ b35is of thls Info alion, or on whether you choose lo furnish ii. If you furnl::h tho infotmatlon,
please p1ovidobolh ethnicity &nd race. For rac,,, you may cheo~ morn _thanone designation. If you d_onot futnish ethnk::ty, race..or ~ex. under Federal
rcguiatlons, th,s lender Is required to note the Informationon the basis of visual obs1rva!!onand surnama 1fyou have made thisappllcahanin person.If you do
nol w!s1110furnish the informa1ian.please che&. !he box belol'I. {Lendermustrevl•w the abovemalarialio assure that the disclosuressatisfy all requlraments
to whlth • fo lh0 oi loa a Ii d for
i 11,Lh'.P.e
n nno l Ut ~ I 1,nrun· s I n 1
F.lhuicilY: Hi!> 11ico in 'Gr.mkllv: Is r.ni 1 atin."'I
nau: O ~1:-~~ai~d""
or D A.lion D ~~~'An1eric:u,
D N:ltiveHownliru1o: (ID Whit: NntiveHownii~, or ILi Whi::
Qflty P~eifiC
Jc ,,,,. I,.., 'fjc t.-:lgotl;r

rri1«c»ip?e1cJ ty!M.110r~~mr:
l~it::;:~:;~:~:!~
0 ta•:drpi11;;;11:claarwh.w
0 QyI\; t.;i.~0111 ~ n:J.'IIU11C.,\::y (:.1 et r:u.1I
{!) fiyt\::: >~".t 64J ,~i:t:4 o:l!i: l(ttNHI
'ti&(->Jt4.I
X
'"i:otiibrtglm1ors s1~tu11Urt Oa:e 4/17/2013
Loin Orlgin.,tor'SNnmc {fitinl o: 1y1~) Lonn Oricino:or ltl:miOer Lc:ui O:igi!'lttot8sPhoneNuMber(indudinc LVC4 Cbde)
A.lron Cl.4~k 222693 (760) 613-1548
Lo:inOriglMUOUCcmpanysNm1c Lo:,nvriciultion Compn:-iy
ldc:11iqcr LoanOriginction Ccmp•ny•,Address
Com~~:, Denk I 002936 ! l920 Glade Road, Collcyvlllo T'X 7603d
D~\mW.co, 7/Dl(r:,,. "°'l
Continuation Sheet/Resid' ntiaf Loan A Jication
Use this conUnuallon ..ro-1·•,a",."-•~,;,,;.:,,.;.;.,;,;;;.;;.;;;.;..;.;;;;:,;.:,:.:..:.:;.::.:..:::::::::::..'...,:~1:;_:::::::;.'.:;~-
shee! if you~:B"."or
need more space 10 comple\elhe DWIGBTL :!IL~ AgenC'J CaseNumber:
Resklent:a! Loan Ap?licallon. I
Mark B for Sorrower or C for Co-Sorrower:
Cc-Cc:rower.
~;Ji;;;;;;;;;;:;-----------1------------+.-~:".'""=---,,.,......,..-------
MAP.J'BEL L. Hil.I,
Lend~rCaseNumber. I
9~3.\322
OS/lG/2013 SCHSCU'L£ OP L.XMII,. rrcs ANO l?LEIXJRD ASSETS

CR.EDITOR'S NJVI.B, ADDRESS ACCT. !IIJl< r:t. HANE
NO. PMT'/ 0?-:PAID
AND l\CCOU?rr NU:-IBER rr NOT 30 0~1Ra•S NOS L2l'T DAt.Af:Cl!

INST;\!.U-tmrt Dfl'DTS
$ ?HT/MOS. $

co. STJ\TEFAR.NCU ACCT U 25S22 90300
iJ>DR. OH.8 STATZ t='AAJ,1PLi\2,\
320. 00
CIT'/ BLOOMINGTON, IL 61110
/24 ill71.00

co. STJ\'i'£1'AA.HCU JICC'!" 0 2ss22 ss1.00
i\Dnn. ONE: STNl'r? ?J\R.~ Pl.l\Zt\ l\CCT NAHi? 191.00
CIT¥ !lLCo.,n:NG'!'ON, IL 61710
IS◄ 101&.-... 00

REVOLVU:G DEBTS
Pltl'/HOS. $

co. CAP ONE ACCT Ii SS:?8S 835J19320U
AD::m. PO aox 8501s ACCT ?l:'\!'ilE 119.00
C!TY RICltKCND~ VA 2l28S
/l5

co. CITr ACCT ii 5<561 00118<6263
MO!l. 70:l S GCTI! ST n I!lS CDV DI3POT ACCT N/\M!? 163. 00
CZ1"l SIOUJ( f:'1\LLS, GD S7104
/n 6027 .oo

co. DISCOVEn P!tl ACCT tt 60110 3551115460
J\O!m. P.:> llOXl5316 l\'M' c;.is P:lOO OEVll!.. ltCCT NAME 35.00
CITY ~IW.WGTON, O!! l!H)S0
/5 172. 00

REAL l,ST/\'f& LOA!>S s Pl-IT/MOS. $

CO. l,vt!l-1 LOhN fl 70800 2157073
AllDR. MOO S1'AGF.COACllCIR l1CCT l/A}lll use.oo
CITY PREOl?RICK. MO 21101 /37 H427 .00

CO. llK OP l-J1ER LOMJ 20999 70
MOR. '1]Cl Fl&~:om· ~K~Y .\CCT NN-tE 1163.00
crr'f G?U?E'NSllO!tO. t:C 27'1!0 /0•

co. CC:·IPJISSDi( !.01'1< It -t'.iSSi 40000'9DGJ6
ACOR. "101 S :i:mn ST ACCT NAM~ 341. 00
CITY BL~lNGH~t, AL 35233 /0• 90967. 65

CO. STATS'Pl\R>!CU LOA.~ ff 25S2l 91900
ADOR. 1 STP.Tl? !'~•I l'!.iiZl\ ACCT t=AHE: JDS.OD
CIT'{ OLOO:.tn:c-ro~!. ?'L cil ll.0 /3' 1-1926.CO

CO. N/A•Othr:r expcnso!l !o~ .>ropc:-ty nt.: LO/lU #
,\OOR. 103 YUCCA .·.ccr >11,ME ,o. -tl
CITY Sl.m.PS!DE !lEACll. TX 17$'11

lfJJo fully-under,tand that 11i$. a Fedora! crfmo punl,h:abfoby !!no or fmprit:aiunontl or ba\h, to kn0win9ly make ony fll!ll,c$tetcmont~oon~crnlngany Cl tna
abovefacts as appllcab!eunderthe provisionsof Tille 16. Unlled Slates Code,Sactl~n1001.ot seq.
eorrcwe(sSlgna1ure Dote Go-El<>rrowets
Sign Dale

X
• r.!''
7)~~4,,(- ,,(. p--e,{
0
6. i7
•
JJ I
~
,11,no10
lJO~SllOl

Continuation Sheet/Resid' ntial Loan A lication
Use lhis continuationshe!l If you Bor;owci: A;ency Cose Number.
nee<!merespece lo completelhe o-..r1G11T L HlLL
Residential Loan Applicallcn. 1-,,---,,--------------+------------1-,-..,..--,,---,-...,.------
rAork s for Borrol'ier01 c for Co-Borrower: LendorCaseNJmber.
Co•BortoYler. M,"\.'\I!lZLL. HILi, 9434322
05/15/201'.; scmmuu:OF l.IABtL IES 11.!IDl'LllDGEO ASSETS

CRED:-ron•s !'Jl'-
...\{E. AOOR£SS /1CCT. }I~ HR, llt"'1E :co. PMT/ UUPA!D
~m i\CCOU?IT UUi◄BER IP t(OT eo, ROWeR's MOS LEPT aA.t..,NCE

Rf:;u. &ST/\'7"2 L.OAH!, HIT/MOS. S

co. ti/ A-Other expense:, for prop<:rcy at: LOF,11 Q
1.!>011.. 110 l.tESM!'t'ff FU\C£ i..0711\-:?ii. ACCT tll\ME 37. 50
CITY StJnt'Sioe 2!:11.CU, TX 77541

co. :1/A·Other exper.ses for pro;,erty ~t, LOl'.N ~
l\DDR. NSS~IT11 PL>.CB LOTlTOJ ~,ccr NiJ..l£ 7.06. 91
CITY SVUYSrD2 sn;:.c,1, TX ,,s,.1

CO. N/h-0:.hcr cxpcn.aco for ptopcr::y at:
ADDlt, lll NESM:T!l DIJ\Cl!/LOT,tlO 137. 23

CITY SlJRl'SIDE BEACH. TX 175-\l

co. H/i\-O:.:hc:- e.xpen.scll !o:: prope.r:.y at.: UlAII b
i\DDR. ?P-SMITH PW\C'S, LOTS 12 ACCT NAM.£ ~so. o,
CITY SORFSIOE BCACH, •rx 7151 l

ALit!ONY /CHILD SUPPORT/SEPAAATS :,.1,UITSN;..tlC£ $ Pl<':/1<0S.

t.axca tor ilOtUtional ;n:opert.1e 709. 56

6052. 70
'l'OTAL ;.tCh"'l"'HLV
'PM:'H.mrrs
227821.Sl
TOT!\L LIJ\J3lLI'r!!:S

WJo fully vf\der&rnra.'fihou it ts :ii F'adornl c.rtm111:
punfahoblo by nno or in,prl•onmont or both, lo knowtngty 1':"lokoony fol:sa :i1a:cmonl;, conae:0105 cny Of tne

300vo focls •• applieo~!eundorlhe p1ovlsionsof Tille 18, UnitedStntosCode. Sec,11
n 1001,et se •

i:,....w:•Lt•c r. .c, tllH
u:i.Uoro Xe,ith~n-:.to.l i..c,n ippU~tlcn _ Kf'S s:...&r.dt!d vc,'1cn ° JOU nuU.od flr-,111.C\&l Sohticr.a. :nc
1)04 91l 0l

ContinuationSheet/Resid nt/al Loan A lication
Usn lhi~ continuationsheet if you Borrower:
nee<!more spnc,, to compiote the DWIG!TTL HILL Ager.cyCese Number.
Resfd2r,tial l.oDn Applica!ion. I'::::-.::=------------+------------+-.,....,,..-_,.,.....,. ______ _
Mark B for Borrower or c
for Co-Bcrtower: l.endgrCase Number:
Co•Borrov;e:. HA!UD:i:L !.,. HILi, 9;34322
05/16/2013 SCHEOULll
OFtl\L GST~l'!: OtlllEO

T'!PS oi;• PR&S£11T AM001'1TOF ,moss T..Y.ES/r.JS
t>ROPRnTY/ MM!CET MO ~-rs !-:ORTGACES run-rrr-\.L HOR-:-c.AGll MATh'T t
J\DOllESS OP ~RO?ERTY S1"A"i"US• Vl\LUE L ,r f. L.IEtlS H!CO?-!E PAYWlllTS MISC. !NCO!le
16-27 ELS!IY i\VE SPO/ ~20000. co 0 l-40S21.81 o.oo 1n10.oo 0.00 0.00
01\LLAS. TX 15209 !I

lOJ YUCCA Other/ 1Gsoov. oo 39 1~ !)26. 00 0 .oo JOS. DO ,o .iJ 0. 00
Stm.FSIOS D~CH, TX 775.t 1

l.18 UESNITH PLACE LOTll1 .. 2A Otnar/ ~5000.00 0. 00 0 .00 0.00 n.so 0.00
SURFS.IDE DEACH. 'l'Y. 77541

!IESM!Tli PLACE: LOTlT03 15000.00 0 0.00 0.00 0.00 ~06. 91 C .00
SUR?S!t:C BRACH, "tX 7?5~ l

ll l !ll!SHITH Pl:J,C!:/LOT9/lC Other/ 165000.00 J:1' 1•1-127. 00 o.oo ll96.00 ll7 .23 C. 00
SlmPSIDl? SBACB. TX 7?5~ l

NESMITH PLl<CE, LOTS 12 Othec/ 595000. 00 0. 00 o.oo o.oo 150. 07 0.00
$.JRPSIO& O~CH, TX 775.C l

TOTALS 1135000.00 19987-i .6l 0.00 3J93.00 1122.la 0.00

• tndic4::c~: H ir: Bor:--cwc":."'Jlr-r1m.1ry Residence. s 1f Sold, PS !f Pending Sale, R ll Rental .being held for lncomc.
N if Subject ~ropercy not includ~d in debt ratios !i.e. Raf nancc)
, • vne;..'!'\ey tac:::or applied

Wvc lully understonothat It Is., Federal crime puni,hnb!e by fine or i:nprl~onment er both. to knowingly ma~e any rslse statementsconcerningany of !ho
abovefactsas applicable
undertheprovisionsoi Tille18,UnitedStatesCode. SccU n 1001,el seQ.
Date

1;rt>Otc Mac. Parm G Cl.tat OtfflS1co.: D'TIC5

Un:.to:-z lto:iill!c:r-.c.i~l c.o:.n r.pplia.tton . HPS .!it.<lndordvcul~t c;i ,cil ll3thl\d rtn•ncial -'Olutl<ln.:i, :r,c.
EXHIBITE

ELSBY MORTGAGE PRIOR
TO MARRIAGE ($ 78,527)
WITH A WATER CLAIM
BEING PAID OF$ 83,583.52,
MADE PRIOR TO
MARRIAGE)
A Washlngton
COMMITMENfLETTER
liiii Mutual

~ •I .._,,.,•l "f1n-r. ')1

c1.;rarr t H::.L

r; ..:.:..,\S, TX 1 1.::i:;
~f •·• l'r PH,f.,.'1\
L;.,, ,,. 41 t1 Fl.SB{ ~'..~

., :, ,_, • •t•ll UI f' ·Lo.an·) 10 tit- u -'f':l t" t• ~ Sr ,,,•,t• ~r.:,.~,ty ,do•,h!..cd ,i:..C .. e, • ,u
FA ,t!lit ·e.ar.i. •• f tP...t':a1no,.J"t1 ... ~ c,,, U-& !e·rii, ilt:f-J ~o- ... ••.l:,lh t 10 :tw: 10 "'""' ,1'J

Purpou Lo..>~ • l,( n, ~i•Jt> l!J •1 )' ,. ,~.'" 0 p t,f\t' Li] ,1! 1 •~-•n-~t- ,, u,,. s.,. ,.it,I.., Prop..-,iy ., , rt~.&r'li..,tA 1..~c-J hO"Y'-- .ar j
•1'1".J • ,rt ,u n •~ ,11"'• \t-.J ~•tot~~ , ),IJI 1'1 •' tr"" Se "'''' Prr,,t'H',t'V
a'3Jrru 1: '",.

1. •1, L'!'IO rt
-;c, , :4 r.,
t ''-'t\' ~A!r {~r -.:-..t □ ••tel•• \ .,,.t'c- R•,,. -I per .a~,rn
,.,,,.. !!_ 000'
ll•rgn C 000'4
-.; ,• R1.1, ~, Q,, rw:1,-onc,,:-o..~d 11-:,<1~p.ar1~~~ Autop..ay
P'.:i,mi. t _ ~ .. ]4 8~ _ !i)Mcmtt-.t, 0fn,hafMonrtvy
L.:4" re<" tllr4l e ,: ('?t.·~

::::l": ~~t satt• ,o locr..-d !or JC: cuyc fro,,, t~c dat<!> or your app! 1cauo.., I! the loan ~s not
c:c.si, ,u,.1 :.ind t;-1• th4t d.>t~. 'fO'JC ir1t~r•1t ~•te will be th• Bank's rate tor Loan• o! thls
typ, <l~ o~ tno date docu,..,e~ts an drawn

Conduon1 lot• flJ ~., rrHc 1 ~ t1t1 p,o.,,'1,..d u,1.irmattOJl to be veulo•-d or 01her cood1tt0riw 10 be &thaf4d • .nclvdi.ng .-.,~ 1.m,1, won,.
·,•;.~ , •r.J ai;:,,a,,,,, wt~1, e,-,,., 1:utri 1bo.-t! t'J• t,.tlow. mu,1 bo etcep11010 anc 1a1,aft:tory to the SUtia.,•n 111•ol• d,...c, ■t,on lr •
Co--n,r11mtnt ,, 1ub1to.:t 10 lf'\e h, o"",,.-2 1e,m1 •"'-' :ol'\0-h.,ll wr.c:h "'"'' be ,at·,t,co puo, to Pf•~••on of dOCumient, t.llC-s>t ~o
c,tr~r.-..,,c tf'\d,c1t1d Any rn,t1tr ,oq..,.11"'0 BaM.'1 1p,.,ov, 1 .,. 1lA~t 10 the B.,..., ,oie 011.cret..::;n

d you a,c g1>1ngto •p~l1; to rn ...io III m1r1ul.c1utNS nornc con,iiIde1cd rt.•I p,openv LS'ldoIap-ohc&b'e l4w. you m\lll p,Ch·,d• 811\A.
1a1,,l1ttory ~v,:j1nco at l~a,, 10 a.a,s. ru>hca p,,01 to uo, nwU.&t o.e ma"\Jtactuted r\C.:ma "-' btRn o, Y!f,V be ptrmtnetnUy 1tt.c:"6d tu
lP'le , •• , 0'0PC:tlf pu,1u1nt tor, ....
P,cpet11 Cod• S.:c,,c:n '} 001 . .,.1th o-..CltltftClle of Ut!.e ,v,,noe,~ to lhl Otpart/T .. OI ot r•••,
tiau,,r~ •NJ Communih A11•111 ar\iS • cie,1,11,wtr- 01 po,maf'",cr,t 1ttae:Pvnent t.fra ,n the teal p,openy ,,cores, ol the c.ounlv ..--htte tt-a
propafff ,1 toc•tod

~I ACCEPTAB:.! COLW.TlRAI. ~PRO",>-!., ll<AT KltET.$ ~;I', GUlDl!Llt;tS, 8Y 1111! LVIO!ll lfJS1' 8!
SUB/oli't"TED PRIOR TO c:.osrnc; AN:> Mi' coio::-:01:s FOR il!PIJR.S 1<.:ST 81! SJ\T:SFAC':'ORILY Mir.
A/ID CCl'.N.!Tl!D lllnl A HINIM\ll-1 PROPERTY V.r.l.UI! OF $~4 1)0 J

PZ:E;?T OF n.oco KA2ARD OETtRHlM.;l'J'.O!: TO rnn.u:>E LIF! or LOAJJ TRAClt!NC

1 Pl!CEI?T OP A 11:lRTGA!il!E'S TlTLl! !l:SUP»IC! PO!..!C'I', Willl ~N S~l!Ct.U EXOORSD'ZN'?'S IO!ICll
n!E B.A!IY. ~.;.y REOUI u, HISURWG 'll!I! 8M'Y.' 5 Sf CURI TY !NSTRL'NEtrr AS J.. VAL:D LIP!J: A.GA:ss-:
TI!! S!C1111ITI

YOUR lh'Tl!IUS1' RAT!! ll!LL Rl!FLfCT I,, 125\ REDUCTION !I' YOU HAVE ClfOSEII TO ?AATICIP:.TI! IN
TIii IIAIIK'S Alfl'O~AY PROOl!»I Alr.OPAY :s A SERV!Cl! n!AT AUl'O(AT!CALLY WI'nCRAlfS nnos
PRGM YOOR OIPOSIT ACCOUNT TO l".AT..£YOUR !.CAil PAYl'IDIT

!,. IP TIU IU1'TlNO SUR!V'Y IS OLDER TIIJ.H 7 YUJIS, A n?!W SVRVIY WILL II! ORDIR.IO POR 5H~
Y!l!S TO TIU IIORROW?.lt

' IIORROlll!A TO PU A COPY OP TW! UT.I oi,i ltXISTINO FlRST L:S>I HOIITOA:l! TO l~4•l!tl•H11

7 1.1 DAY COLLll;Q OFF rrn1:.:1, !.!,7) J <;;;,y R!CH:- Ot ~.1:s:::ss101; Afl'!.H.S

\)J
LCNlff
Numbor: 00l87Ul09

~~~ lnlUIOMO: All lnsurancamust be in tc,m and i111uodby c~mpanlo11acceptableto tho 8w naming Sank u lost poyee. ift 11
aeceptabla to \ho Bank. U we odvtaeYoU thot the Socurnv Propeny ia located tn O fedofelly deeiona1edFlood Hazard a,ca
; p011t1on
FroodH1101dlnauus~ce 1.11roqulrod. You wiU bo rCQUiredto provldo tho Bri with 8 policy o, polic:i.t or 1 """°"'°
qainst fito and
•astendo4 coverage pctd1 In on amount which ts 11 lotlal equal to tho topllccmont cc11 of tho Soc:unty P,openy or 1hoLoan Amount,
~htc:hOVIIIJ' 11 IOH,

II \ho Security P1oper1ycncludoa D m1uwf11ct~rcdhomo, tho cabovofiro and o~tendcdcovorogopolicy mldt bo undo, o m4nuf.oe1urod
homo polley• Vou may provide tho ,oqwact propertyIMurmco tlvauohuktfnopoScla. or you may purc:haethe recprcdfnsurance
waudi my lnavnsnoo company CU1horiitd to tr--..cl buslnet• fn Tous that r. reuDl'lably IOClplable to Balle.

Advau Chanea In FlnandafConddon: Lender tetet'\11'1 tho right to vorify and reverify !nfonnalton 1ubmiltcd cfurin9
Iha loon p,ocoos.
Lander shall ha~e tho right 10 rescind lhat Commitment with no further cbliptJan to mako tho loan: c1t In 1ho ovonl of a ma1orial
change in vourcn:dil or financial condition prier to tho expiration of tho Commitment; 12Jin tho ovont of a matoriol change 4111he
votuo, lien poaltlcn, o, condition of tho Socu,ity Property prior to lhe oxpitotion of this cOtnmitmont; Cll In the e,,,ent Lendordircovon
cvidonco Df mitrepraontaticn er emission of material foct in connection with you, fDan appticatJOner any a,pect of tho cantempfalcd
tronsoc:liOrt:or. t4, to shit eX1ont pe,mittod by low. in the event of minlInoriat. c:lorleal. 01 cabaauon oner m 1ho p,ocoHing or
undorwriting of your lo11nroqunt or iHU&ngany commitment or In tho ovont of o mi1quoto in your pricing pac:kogo. Nohvhhstand"'i
anything to tho contrarv In any e4mmitmcnt. c:ondit10MIcpp,ovol. « othorwtao which may bo IHued by Lande,. thowl your finAnclol
1nautu1ionrot"'n your ctwck for ony foo rolatod horo10.including witnout t1mi1.1nsutfu:lent funds. payment stoHed. ot oc:countdosad.
Lendor shaUhovo tho right. at ii• discroticn. to dony tho Loon. romovo the lnte11estrate ?ockm1dto ,usue cny otnet remedy Available
at law, equity. Ot othorwitet.

A11lpmcrnt: Thi• Comrmtmont is mado aolcJy t<>the obovOn11tnod 8onoworts1 end may not b6 aHigncd and thaD tonninato in tho
ovont of on ot\ornpt by you to u11;n 1t too third party. No third parties are entitled to rol'( on this Commitmelftl.

D~t• tetmt endcondl1JGns
and Closlftt:All dOc:urnent•and terms not tpec:sflOdhln!n sh411bD lha Bllllk'1 11.ll'ldatd for CIIloon of
this typo And muat bO aatistoctory to BaN. Tho Loan wiD bo do1od by tho Bank o, olhar aon.lctnent egen1acceptablo to tho Sonlr,.

Eaplraclon: Tho Bank ahall hovo no obkgatiOft~ this CommitfflCnt and oll faa proviously colleclod wcl2be MfflOdunlal aB 1M
obOvementioned condctiOMhave been 1otisfled. enfull, DDrequited doeumertll •IGMd and whele apjlt0pria10. fded a, rocon:Sedprtar to
30 days ltom tho deto ol thit lomtr t•ExpsratiOnDato•). If this Loan Is e&lbjoctto thD Woo clay rtahl to rac:ind undot tho FDdctal TMh
In Lending Ac,. 1hothroe daya must exp1roboforo tho Expi,otlon Ooto in Ofdcrto allow timo lo, fundinQand rcco,ding.

AdditioMI C*: Vou mldt poy H ap:plicoblooll lawtully pennit1ed casts and other charget lncurrod in camocaon wrUI tho Loan
in:lud1ng. but not 11M1tedto, title tnauranco prOMiums, app,oi,ol. lnlpaction flood IOMc:hlftd vuctinO, AUamoy fooa. fllCOldina. fifing.
oihcr iJOVGrnmantal end lcndat fee•• b&aodon Lcndol'• too policy oppficebloat tht tltno of tNt commiUMn1. aulljoct 10 logal limds.

Sy Dato
FREDROOMIAHl 01/09/2002

NOTICE:THIS WRITTENLOAN AGREEMENTR£PRES£M'STHE FINAL AGREEMENTOF THE PARTIESANO. TO THE EXTENT
PERMITTED av EVlOENCEOF PRIOR.CONTEMPORANEOUS.
8V \.AW, MAY NOT BE CONTRADICTED OR SUBSEQUENT OAAL
AGREEMENTS OF THEPARTIES.THEREARENO UNWRITTENORAi.AGREEMENTSBETWiENTHEPARTIES.

I ACCEPTTHISCOMMITMENTON THETERMSAND CONDITIONS
STATEDABOVE.

DWIGHT
L HlLlt

BORROWBR
COPY
GOOD FAITH ESTIMATEOF BORROWER'SSETTLEMENTCOSTS
(FOR CONSUMERLENDING)
OOJ8 743109
C,• • ~TJ.Tf
D4llAS, TX 7~109
occ ...•A-1-:1 ''l"tf" IU.'I 'I""' .,,_,_
.....
0&.J•a..u.t, □ c,-..,, ...:H:,,r.,-~•.-, ,..,... .;..f\.•ftr.f @o-M• &il'O' • 16),.,,c O.- 1'0
•••\tllo" V!"'"XI
l!} A...;TOll.t.1
fr.rt 11 en Htme\1 or n.o,t of lht th•Qit• -you wli h...,. 10 Jt•l •t the doeng 1•••1demen1·1 of y0411 loaf\ r~ r.gwet ahO.,_fl •• ettwnetn ana
rti•1•te11 at• ,..it>,ec:tto cha-.,g.e. The a,1.-n1tt1 .,. ,omp-ut•d on • •••• P"c.•'■ttfflated ~Mf• of tl• 0£)() ;,j:j Mid a ptopo,.-d LO,er\ ot
12§00000 -- ,,. --

GOODft.lTH ESTlW1E Of SETT.EMWT COSTS•• teqv,ed by fod••• l•,.. Th• numbe,t., 1«11 ,olumn co,rnl><>"d to the'"'•-~•°" IN
NUO l S,t-uemtnt $tatetnent ~'tuch w1'; tA uled .., c.on,unct.on Mth tt'la tfi)l"'O of vour loan. '°' tuon.u ,&p111n.a1,onof theta c.h•Ot• conis.utt vou,
r.,ooa11t .nttU.d '"Stt1lo:i'\1n1 Co111 and Y0u. • HUD Gude fOf Hom1bUytt1 ••

801 Loan Orog•,a11on f&.1
LOANotAIIGtS
901 ln10, .. 1 (1 day
Pll!PAl> ISCIIOW CtlJUIGfS
,g '12 I
..
I QOOO ,1 15 day, ..
8()3 App111ul fee • POC ,1n w 903 Huord In, 1ti Yr PTem
BOSln,p~c1oon fee 90.C Flood lntur•""•
1101 Setllement or Cl0>1r>g Fco 905 Wind lnaur1nc<
110!, Su1>ord1nat10n Foe
l 108 Title lr'llurarv.f\ 11ESERVES DEPOSITED WITH LENDER I

l~en.1er·1 Co>1cuagr1 POC 11 17~ 0C qc,etvt.~ 1o
1117 Sa!> E,e,c,w Fee Bo Colloct~<l
0 Ho, 1n, Dr .... (!1 Nono,
I 201 R,cc,1d.ng f OCI POC \~6 00
; lO' $Jr;ey Fee ,n~oo
l 305 fi:>OIJ N.a1aro Oeu:rrt11r.01,cn POC \ 13 00

'
I
TOT AL PREPAID ITEMS
.. The actual amouru w• bl '1e1•nlf\.d bv ~h day cf the mi:.in1h
I ~ Jo&."\ac:tua::ty c.fa,u

i Ad,v11men11 fc, r•el u-..1• 1u•• tllf'ftae.hndude p,cwac.i tu••
- .. ~
«;< ~•A •rn CLOSlhG COSiS \7%00 .-.J1<Jt any•"- runbUf•ef'l'tM'll •• 001 lt\C.Jud-,

~~ Pa~ Outc.,d• ~, C~u'"IQ s, ml'I lu1. r- :a.,~• mati.N POC Tt-o.e cou\4 1~eun1 tel toan cost, P...:, t7"ta.,._'"' connecuon w,u, • "No eo.1·
'. "' It ~ It, ,,.., f. 'l '( ti f: lt''"l'hH l- .,e,:a•J lf•'lll~At C"' oma, ·.otll ~•.d by""· bonow•r OUllda OI Defoe• CJoll"\CJ,.-UltJam-u. Any .uc.h ~·--
"· r • t ~ 1,.4 ... attJ 'l'\I y\..;t Total [at ~•t•d Ck,aang Ccah
NOIIC[ THIS fDRM OOES NOT cove~ ..,L ITEMS YOU MAl BE RlOUIRlD TO PAY AT SfTTUMEKT YDV MU WISH 10 INO\/IIIE 4S TO THE
AMOUNTS Of !>UCH OTHER ITlMS THIS IORM IS Nfl1H£R A TRUTH IN lfNOING OISCLOSUIU STATEMENTNOR A COMMITMlNT10 EXHNO
flN,ltlCJNG
ESTIMA HD FUNDS TD ClDS~PROCHDS
I ES T'U.V.TED t,40"11Hl'•
Pr,t"l(;1yal & ln1c1e,1
lDAII & PES[R'✓[ p,. YWEPH
111•,2 (Y'; e Purr.h.ne Pru:,: or Eius.tino L,,.,n,
{lo L<: p~1~ olll '7B2lZQQ
I Ren1t~tatc- l o•c,
H.au•j 1, ,u•;Jt\C~
s
s
Flus
Plu~
T01a1 Clo~,n,g Co•tt

Prt1~1d lltms
IZ2~l:!2

I o,,.,,. Olllrt

Q•tic,
$

!.
$
10TAL
t.uJo•
les1,
LOJ.n Amouo\
Dc,-0•111
-~
•. r
------
,~,. ~l~"

t.,.tf,cr s
I 0m
Leu 01he, F,n.aoc•"Q
(1uh RcQutcd I.> (l<Hc
'
..... l"' ~
r
?rocc-c,Js. oil C•:h•~•J 11£:!IJ!X:r
-- -
t .,..,
P~RllCULAR ,ROllllliRS OF S~RV1Cf REQUIRED Tt•• ._r..,\)•' .,..,,1., •1-4 S'I 1t,• Uu.:.J J:,..,1h E,hna1e at.o .. • .,. .;J#<,,ri ti'<• c.w•a,:,ondng
•.;t!I I l •• J•. _r.,tcJ ~ ,'1.1\ J&l· t,f ... ! l,,f, JU

f rtt,1 bJJ' ,.o fhf ~'• .... ,"p•H, •.• .... ,"'-,r. ,.,. .... Wil 00 1..""' orea D\ an ~.,,, ... ltc;m Lend•' ,1 COttlJ(Yf~~, ,.,, fr• ,.,..g• 11 •:,0 00 10
,,. •• ...,..G-Y'\~ ,.r ... 1.,J ,.,, 1.n• llOJ
•' .r,nc,c '•l'""'Cl'""I
,rL,.~ ,jo
<I"•• c;v•r•""L,

~ • . "'l
-0•1•-nal• , w' '••

,,Jot.'! AOi;)f\£:>S
1, t.•

- THfl'WONf·
16281966-0616
lll'!TA c011,01u,T1CH 1123 5 PAR• Vl[W OR COVINA, CA 91124
~C\Ah\it,.,t1!Pl ti) •.,,f5i C '") t,A i\JAf: Of Rf.LA llOUSttlP T""41 S..M ~• ,..,..1-edly u-.d o, ,.....,_. borrow~• to~-
I .. ~ ol one of lNM p10'-'ld•r• •flh&n ll'wl Lui 12 month•
I
r-,t'•' ,.o ~t,4 UA\"l AO:>kl~S
--- ltlfP><ONE
CHAS! CREOrT 63!,0 LAUR[l CAN•ON DLVO NOI\Hi HOLLYWOOD CAu,oRNIA 91606 18101 762-l;ZU
UPIRIAN. 101 lXl'£1\IAlj ~ARKWAY PO BOX 2002 AUIN TtXAS 7&01l OOJa 1-eaa.397.31,2
I EQUIFAX INC 1600 l'fAChTRf[ ST NW 4Tt.ANTA OU)IIGIA 30309 14041 88!>-8000
I •~L,HIDNSti,~' @vi~ QNO NATURf OJ REI.ATIOI.Sr<IP TM &anl h,U t•~a1...Sf'r ut+d Of , ......
.. n-tca• ol o,w of u. .. p10Yld••• .,_.t\han er. la•I 12 mona,,a
bono-,ar,.,.. 10 .,._

-• , •V"> •.•
tt-4
wuo
1..-,, t C' twaJI
c,t\ \J .. ,u,..-,,
li,IKJJ,.._ U¥\t":tl,ll'I
.,,., •• , ••U "" 1"'41 l'W'P• ,j!
lrt tt-.e C.fU
~ fu, .. NC.h ~ N'fl
,I .&'"I ad,.,1f1bf• UI• l'Tl0tl~IV,. lhl
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t~Jel
TLu'
lflCfU-'
Kh,-al ,.1.
1 11"11t,le
,,. .... .,,,.," ~"".De .-..ub6:ah.d
le, ~ ..,.\-,.I -3fU\lrn.t'\l ~
bu.cf Ur\

r .:u ••In"..-~ ... ~- ;:.•.,.;Je,d ~h.-f"'I ,., If'•''-• t ··•t• ~•lllwnttll PrO<■dUf .. 44:1Of 1!1'/1. u .-r.-vJed 11-U~· Al ~-l,ol\a,1 -,h,:jl'n-◄1~ (;a,\ t... lt,r,.t1(j 11"1i, ...
,. o,I .. ~ ....... It'll m,,"'..,, ,., .-.f'l'J, I\.• be r-1.1,'1t..: IU '"" tr, fOVI ~w
/ ,
:/

I D•TE

BORROWER
COPY

·-
Fire loss Details
Losses Paid

causeof loss: AmountPaid Subrogated
Amount

Water Damageor Freezing• Building 72,750.56 0.00

Water Damageor Freezing- Personal 1,009.00 0.00
Property

AdditionalLivingExpenses- Time 9,823.96 736.00
Element

Total 736.00

From:Dwight Hill
Sent Tuesday,March-28,2023 8:05 AM
To: Maribel Hill <maribelhill@gmail.com>
Subject: all claimson 4647 ElsbyAve Dallas,TX 75209

1
DLH-004539
06-09-2019 43-9534- No WIND/HAILBLDG CLOSED 0.00
Fm)

09-13-2015 43-746N- Yes MYST/DISAPPEAR .CLOSED 3,525.00
928

01-19-2001 43-8787- Yes WAT/OMG/FRZBO CLOSED 83,583.52
251

From:Maribel Hill <maribelhill@gmail.com>
Sent:Monday, March 27, 202310:22 AM
To: Dwight Hill <dwighthill1003@gmail.com>;Dwight Hill <dwight.hill.cffk@statefarm.com>
Subject:[EXTERNAL] 4647 ElsbyAve Dallas,TX75209

Good morning Dwight,

I need the claims history and file history of my property 4647 ElsbyAve., Dallas,TX75209 since its inception being
insured with State Farm.This includesyou as agent, since 1998.
I was a client with state farm under my old married name, Maribel Haasas well... and this home was included in that
under another agent.

Thankyou.

Peace,

Maribel Hill
c: 214-727-57S4
www .maribelhill.com

2
DLH-004540
EXHIBITF

FUQUA REPORT VALUING
BUSINESS AT $ 728,000 AS
OF 2022
FARMER, FUQUA & HUFF P.C.
\t c, 111nt.InI, .,ncl ( , ,11,11/t.1111,

.•• , <,·•u I ..,,, '.1 I' .' I ; I - I ~• l
-~ I t ,I "'' 1,-,.1, ...-,,l ~ ) f 'l : ,1-: :1, 1-

DWIGHT HILL INSURANCEAGENCY INC.
FAIR MARKETVALUATION ANALYSISOF 100% INTERESTIN

DWIGHT HILL INSURANCEAGENCYINC.

AS OF DECEMBER31, 2022
The services performed in connection with this engagement do not constitute an audit, review, or compilation of the Company's
historical financial statements in accordance with auditing standards generally accepted in the United States of America, nor do they
constitute an examination of prospective financial statements in accordance with standards established by the American Institute of
Certified Public Accountants. The services also do not address the effectiveness of internal controls over financial reporting under
Section 404 of the Sarbanes-Oxley Act. Also, except for ascertaining that certain information in tabulations and reports received
from the Company agreed with the accounting records, we performed no procedures to evaluate the reliability or completeness of
the information obtained. Accordingly, we express no opinion or any form of assurance on the historical or prospective financial
statements, management representations or other data from the Company included in, or underlying, the accompanying
information. While we believe the information obtained is substantially responsive to our requests and analyses, we are not in a
position to assess its sufficiency for your purposes.

EXHIBIT

P-26

DLH.SF-002855
FARMER,FUQUA & HUFF P.C.
\( ( l/f/11/,1/)/, ,P/J(/ ( (lfl,(llt,111/•

'. t , I nt I ,1,·. ',1 ·, • t I 'I~ ,- " I
!,, I rl• ,, 1 ,,,.1, -;, • I '1 I 1-; ::1 ,-

Dwight Hill Insurance Agency Inc.

Valuation Analysis as of 31 st December 2022

Conclusion
of Value
l=Considered & Used
Indicated 2=Considered & Rejected
Valuation Indication by Method Value Weight 3=Not Considered & Rejected

Book Value Method 0 0% 2 Considered & Rejected
Capitalization of Earnings Method 728,000 100% 1 Considered & Used
Market Data Method - Bizcomps 748,600 0% 2 Considered & Rejected
Subtotal 728,000
Personal Goodwill Discount 80.00%
Calculated Conclusion of Equity Value 145,600

SELECTEDCONCLUSIONOF EQUITY VALUE 145,600

1

DLH.SF-002856
FARMER,FUQUA & HUFF P.C.
\1 ( IJl//l/,l/1/, .111(/ ( 1111,11//,111/,

: l,' 'f"I\I I., •,, I J 'I : ;- 'I I

: ,I ul\nl\ ~,-,.l.. ·ltl:' l '1 : ,1- • : 1•

Historic Income Statements
Year Year Year Year
Ending Ending Ending Ending
December December December December
31,2019 31,2020 31,2021 31,2022

Revenues
ServiceSales 331,790 329,888 335,274 371474
Total Revenues 331,790 329,888 335,274 371474
Operating Expenses
Advertising 15,801 5,347 5,318 13,977
Automobiles 15,952 9,080 21,065 22,843
BankCharges 426 350 292 225
EmployeeBenefits 19,933 21,110 26,122 21,268
Insurance 10,584 11,072 10,002 14,418
Legaland professional 1,665 1,751 1,818 2,130
Depreciation 32,425 19,290 66,215 925
Office Expense 1,735 1,320 6,512
Rent 14,109 14,383 15,962 16,370
Repairs& Maintenance 3,646 1,917 1,489 3,209
Officers' Compensation 77,867 95,062 76,335 73,724
Salariesand Wages 8,460 8,464 5,333 10,088
Utilities 970 1,608 625 3,279
Taxesand Licenses 99 8,408 8,280 3,339
Pension,profit-sharing,etc., plans 400
CustomerResponseCenter 1,137 1,137 1,135 1,134
Duesand Subscriptions 536 615 140 849
Meals 5,414 4,642 7,282 7,049
Petty Cash 3,558 2,500
Postage 86 171 34 399
Security 50 266
Supplies 9,848 7,939 7,864 16,880
Telephone 5,070 3,916 5,339 3,986
Training and Education 7,816 4,833 3,412 1,541
Travel 458 2,436 1,637 1,570
Payroll 1,673 3,316
BusinessExpense 270
Total OperatingExpenses 237,995 227 401 274,150 222,789
Operating Profit 93 795 102,487 61,124 148,685
Other Income/(Expense)
Other Income 14 952 19 535 2
Total Other Income/(Expense) 14952 0 19 535 0
Net Income/(Loss) 108,747 102,487 80,659 148,685 DLH.SF-002857
FARMER,FUQUA & HUFF P.C.
\( ( l/fl/1/.1/J/, ,/11(/ ( ll/1'1///,111/•

'· • , 1 ,,: I '·I''• ,,. •t 1 1 'IJ: 1- .t ,
,!111 !f'HI ;, ... 1,•~,tt/) ~ '1 I 1- : :~4 t,-

Adjusted Income Statements
Year Year Year Year
Ending Ending Ending Ending
December December December December
31,2019 31,2020 31,2021 31,2022

Revenues
ServiceSales 331,790 329,888 335 274 371 474
Total Revenues 331,790 329,888 335,274 371 474
Operating Expenses
Advertising 15,801 5,347 5,318 13,977
Automobiles 8,540 8,540 8,540 8,540
BankCharges 426 350 292 225
EmployeeBenefits 10,000 10,000 10,000 10,000
Insurance 10,584 11,072 10,002 14,418
Legaland professional 1,665 1,751 1,818 2,130
Depreciation 7,000 7,000 7,000 7,000
Office Expense 1,735 1,320 6,512
Rent 14,109 14,383 15,962 16,370
Repairs& Maintenance 1,000 1,000 1,000 1,000
Officers'Compensation 0 0 0 0
Salariesand Wages 107,650 107,650 107,650 107,650
Utilities 970 1,608 625 3,279
Taxesand Licenses 99 8,408 8,280 3,339
Pension,profit-sharing,etc., plans 0
CustomerResponseCenter 1,137 1,137 1,135 1,134
Duesand Subscriptions 536 615 140 849
Meals 5,414 4,642 7,282 7,049
Petty Cash 0 0
Postage 86 171 34 399
Security 0 0
Supplies 9,848 7,939 7,864 16,880
Telephone 5,070 3,916 5,339 3,986
Trainingand Education 7,816 4,833 3,412 1,541
Travel 458 2,436 1,637 1,570
Payroll 0 0
BusinessExpense 0
Total OperatingExpenses 209 944 204,118 209,842 221,336
Operating Profit 121,846 125,770 125,432 150,138
Other Income/(Expense)
Other Income 0 0
Total Other Income/(Expense) 0 0 0 0 3
Income Before Taxes 121,846 125 770 125,432 150,138
IncomeTaxes 0 0 0 0 DLH.SF-002858
Net Income/(Loss) 121,846 125 770 125,432 150,138
FARMER,FUQUA & HUFF P.C.
\c C lll/lll,1/l/, .,ncl ( r,11,11//.1111,
•..:; , , ,.r,r I ·,p\ '-., •·• \ ( I' 'I ' 1-1. 1 l
.:{111,,,,1,,,11 1,-,.,.. --;n .t> I > I : 1-: :.:1111-

Common Size Adjusted Income Statements
Year Year Year Year
Ending Ending Ending Ending
December December December December
31,2019 31,2020 31,2021 31,2022

Revenues
ServiceSales 100.00% 100.00% 100.00% 100.00%
Total Revenues 100.00% 100.00% 100.00% 100.00%
Operating Expenses
Advertising 4.76% 1.62% 1.59% 3.76%
Automobiles 2.57% 2.59% 2.55% 2.30%
BankCharges 0.13% 0.11% 0.09% 0.06%
EmployeeBenefits 3.01% 3.03% 2.98% 2.69%
Insurance 3.19% 3.36% 2.98% 3.88%
Legaland professional 0.50% 0.53% 0.54% 0.57%
Depreciation 2.11% 2.12% 2.09% 1.88%
Office Expense 0.52% 0.40% 1.94%
Rent 4.25% 4.36% 4.76% 4.41%
Repairs& Maintenance 0.30% 0.30% 0.30% 0.27%
Officers' Compensation 0.00% 0.00% 0.00% 0.00%
Salariesand Wages 32.45% 32.63% 32.11% 28.98%
Utilities 0.29% 0.49% 0.19% 0.88%
Taxes and Licenses 0.03% 2.55% 2.47% 0.90%
Pension,profit-sharing,etc., plans 0.00%
CustomerResponseCenter 0.34% 0.34% 0.34% 0.31%
Duesand Subscriptions 0.16% 0.19% 0.04% 0.23%
Meals 1.63% 1.41% 2.17% 1.90%
Petty Cash 0.00% 0.00%
Postage 0.03% 0.05% 0.01% 0.11%
Security 0.00% 0.00%
Supplies 2.97% 2.41% 2.35% 4.54%
Telephone 1.53% 1.19% 1.59% 1.07%
Training and Education 2.36% 1.47% 1.02% 0.41%
Travel 0.14% 0.74% 0.49% 0.42%
Payroll 0.00% 0.00%
BusinessExpense 0.00%
Total OperatingExpenses 63.28% 61.87% 62.59% 59.58%
Operating Profit 36.72% 38.13% 37.41% 40.42%
Otherlncome/(Expense)
Other Income 0.00% 0.00%
Total Other Income/(Expense) 0.00% 0.00% 0.00% 0.00%
Income Before Taxes 36.72% 38.13% 37.41% 40.42% 4
IncomeTaxes 0.00% 0.00% 0.00% 0.00%
Net Income/(Loss) 36.72% 38.13% 37.41% 40.42% DLH.SF-002859
FARMER, FUQUA & HUFF P.C.
I<c 111uII,1111, .111(/ < 1111,ult.111I,
,.; l , t ,•n: 1,,r. •,11.·1 l t I If : } -, , ( '
'u I rrf,,,,, y,..\,I .. -;,11! 1 ) I '111-·1<•11-

Capitalization of Earnings Benefit Stream

Year Year Year Year
Ending Ending Ending Ending
December December December December
31, 2019 31, 2020 31, 2021 31, 2022

Adjusted Pretax Income 121,846 125,770 125,432 150,138
Add Depreciation/Amortization and Other Non-Cash Expenses 7 000 7 000 7 000 7 000
Total 128,846 132,770 132,432 157,138
Weight 2 3 4 5

Ongoing Earning Power 140,816
Less Ongoing Depreciation/Amortization 7,000
Taxable Base 133,816
Less Estimated State Income Taxes - Effective Rate: 0.00%
Before Federal Taxes 133,816
Less Federal Taxes 0
Subtotal 133,816
Depreciation/ Amortization 7 000
Adjust for Working Capital Requirements
Adjust for Capital Expenditure Requirements -7,000
Adjust for Long Term Debt Requirements
Calculated Ongoing Benefit Stream 133,816

SELECTEDONGOING BENEFIT STREAM 133,800

5

DLH.SF-002860
FARMER,FUQUA & HUFF P.C.
\c <,n111t.111/, .,ml ( on,11/t.1111,

,.; JI' ( .-n, l I ,r .. ..,, 0
1 ( I 'I 4 1-\ ~•
1~••I ,,,J...
.,n ",-,.1.. -;11 .r) • '1 : ,- : :,{1 ,-

Capitalization of Earnings - Capitalization Rate

BUILDUP CAPITALIZATION RATE

Risk-Free Rate of Return 4.14%
Equity Risk Premium 7.17%
Small Stock Risk Premium 10.99%
Plus/Minus Industry Risk Premium -2.37%
Company Specific Premium 2.00%
Net Cash Flow Discount Rate 21.93%
Discount Rate 21.93%
Sustainable Growth 3.00%
Capitalization Rate To Apply To Next Year Stream 18.93%

Selected Rate 18.93%

6

DLH.SF-002861
FARMER,FUQUA & HUFF P.C.
\c < 111111/,1111, .ual ( 1111,11/t,1111,

•.; f 1' ( l·llt f •.fl\ ',1 't ( J l 1-t ,- 'I

~" I 1ul• ,,, l,-,.,L. ...1,1 ,) I I l I 1-; l't 11-

Capitalization of Earnings Indicated
Value

Selected Ongoing Benefit Stream 133,800
SustainableGrowth Rate 3.00%
Benefit Stream 137,814
Capitalization Rate 18.93%
Indicated Equity Value 728,019

SELECTEDEQUITYVALUE 728,000

7

DLH.SF-002862
FARMER,FUQUA & HUFF P.C.
\( ( 01//J/,IIJ/, ,/11(/ ( (1fl,llft,111/•

: S , ( ,·nr. I ,t" ',i.r', 'I, 1-1. 1 ,l

a,1 I ,,to..ofl ;,., ........ ., ,,, '1 I 1-: :,t, 11-

-·
Comparable Transactions Method - Blzcomps Selected Transaction
ID SIC NAICS BuslncH DHcrtpUon Reven!MI SOE Ice/ Reven Price/ SOE State Sale oat·•

07874 6411 524210 HealthInsurance 510 210 340 0.67 1.62 FL 1/31/2016
07841 6411 524210 InsuranceAdministrator 263 263 378 1.44 1.44 FL !>'1/2017
07913 6411 524210 InsuranceAcrnlnlstralor 259 134 400 1.54 2.99 FL 3/1612012
07885 6411 524210 InsuranceAaencv 325 125 285 0.88 2.28 FL 5/31/2015
07890 6411 524210 lnsl.l'anceAaencv 450 220 1040 2.31 4.73 FL 12/31/2014
07899 6411 524210 lnsLranceAoencv 558 281 960 1.72 3.42 CA 81612013
07838 6411 524210 Insurance Aaencv 200 70 480 2.40 6.86 FL 9/30/2017
07831 6411 524210 lns1.Kance Aaencv 597 268 1 350 2.26 5.04 GA 5/30/2018
07823 6411 524210 lnsll'anceAaencv 447 179 1 033 2.31 5.n FL 11/29/2018
07824 6411 524210 lnsll'anceAoencv 447 226 1 033 2.31 4.57 FL 10/31/2018
07826 6411 524210 InsuranceAaencv 332 72 565 1.70 7.85 VT 9/14/2018
07875 6411 524210 InsuranceAoencv 365 91 380 1.04 4.18 FL 1/31/2016
07876 6411 524210 lnsll'anceAaencv 778 453 1 300 1.67 2.87 FL 1/15/2016
07870 6411 524210 InsuranceAaencv 283 69 410 1.45 5.94 PA 3131/2016
07873 6411 524210 lnsll'anceAaencv 413 97 475 1.15 4.90 FL 2/612016
07851 6411 524210 lnsl.l'anceAoencv 234 117 550 2.35 4.70 FL 4/30/2017
07853 6411 524210 lnsl.J'anceAoencv 202 101 440 2.18 4.36 FL 3/31/2017
07854 6411 524210 Inst.raneeAoencv 265 105 585 2.21 5.57 FL 2/28/2017
07855 6411 524210 lnsl.lanceAaencv 302 197 585 1.94 2.97 FL 2/28/2017
07864 6411 524210 InsuranceAaencv 687 93 280 0.41 3.01 TX 7/18/2016
07877 6411 524210 InsuranceAaencv-Auto 365 91 380 1.04 4.18 FL 1/8/2016
07882 6411 524210 InsuranceAaencv-Auto 307 200 7:50 2.11 3.68 FL 10'1/2010
07881 6411 524210 InsuranceBroker 347 205 755 2.18 3.68 FL 10/31/2015
07840 6411 524210 lnsl.l'anceGeneral 245 70 484 1.98 6.91 FL 9/11/2017
07867 6411 524210 Inst.raneeGeneral 218 66 400 1.83 6.06 FL 6/26/2016
07856 6411 524210 InsuranceGeneral 424 268 780 1.84 2.91 FL 2/22/2017
07822 6411 524210 Insl.l'anceGeneral 447 179 800 1.79 4.47 FL 11/29/2018
07891 6411 524210 lnsl.l'anceGeneral 339 159 635 1.87 3.99 FL 10/31/2014
07915 6411 524210 lnsixanceGeneral 428 304 525 1.23 1.73 FL 2/13/2012
07868 6411 524210 Insurance-Adminlstrator 558 93 380 0.68 4.09 FL 6113/2016
07858 6411 524210 lnsurance-Au1o 226 172 450 1.99 2.62 FL 12/1/2016
07819 6411 524210 lnsurance-Aulo 575 320 700 1.22 2.19 FL 1/30/2019
07820 6411 524210 Insurance-General 667 417 2000 3.00 4.80 FL 12/13/2018
07821 6411 524210 Insurance-General 447 226 1 033 2.31 4.57 FL 11/29/2018
07816 6411 524210 Insurance-General 377 209 610 1.62 2.92 FL 7/1/2019
07828 6411 524210 lnsurance---General 224 69 300 1.34 4.35 FL 7/26/2018
07825 6411 524210 Insurance-General 690 460 2 070 3.00 4.50 FL 9/28/2018
07832 6411 524210 Insurance-General 227 130 450 1.98 3.46 FL 511/2018
07835 6411 524210 Insurance-General 280 188 150 0.54 0.80 FL 1/17/2018
07837 6411 524210 Insurance-General 229 92 410 1.79 4.46 FL 11n12011
07839 6411 524210 Insurance-General 375 205 1220 3.25 5.95 FL 9/29/2017
07842 6411 524210 Insurance-General 265 65 133 0.50 2.05 FL 8/31/2017
07846 6411 524210 Insurance-General 424 144 800 1.89 5.56 FL 6/26/2017
07859 6411 524210 Insurance-General 797 160 1200 1.51 7.50 FL 11/30/2016
07865 6411 524210 Insurance-General 584 53 400 068 7.55 FL 6/30/2016
07866 6411 524210 lnsurance--General 584 53 400 0.68 7.55 FL 6/30/2016
07871 6411 524210 Insurance-General 274 115 250 0.91 2.17 FL 2/29/2016
07872 6411 524210 Insurance-General 273 115 250 0.92 2.17 FL 2/29/2016
07916 6411 524210 lnsurance--General 360 198 375 1.04 1.89 FL 1/5/2012
14223 6411 524210 Insurance.General 660 426 2170 3.29 5.09 FL 2/9/2021
14279 6411 524210 Insurance-General 217 147 470 2.17 3.20 FL 1/14/2021
14351 6411 524210 lnsurance--General 221 114 220 1.00 1.93 FL 614/2021
14902 6411 524210 Insurance-General 468 226 1226 2.62 5.42 FL 9/28/2021
14903 6411 524210 Insurance-General 226 156 324 1.43 2.08 AZ. 7/15/2021
14904 6411 524210 lnsurance--GeneraJ 420 245 475 1.13 1.94 FL 6/30/2021 8
07896 6411 524210 Insurance-General 208 137 60 0.29 0.44 FL 12/2/2013
07897 6411 524210 Insurance-General 329 157 700 2.13 4.46 FL 11/1/2013
07906 6411 524210 Insurance-General 362 59 375 1.04 6.36 FL 10/31/2012 DLH.SF-002863
07907 6411 524210 Insurance-General 275 149 300 1.09 2.01 FL 9/19/2012
FARMER,FUQUA & HUFF P.C.
\c c ncmt.101, .,ml< u11,11//,1111,
.: 11' ( ·nl 11'-f"• ',1 ~, ( I '14 1-1,1 }
~14 t .,,1 ...,,, i,-,.,...-)0,tl' I I l I 1-; /11 11-

BIZCOMPS Indicated Value

Revenue SOE
Multiple Multiple

Base 346,600 140,800
Multiple 2.23 5.23
Subtotal 772,918 736,384
Weight 1 2

Additions:
Cash 0
Accounts Receivable 0
Inventory 0
Real Estate 0
Other Current 0
Net Intangible 0
Other Non-Current 0
Subtractions:
Accounts Payable 0
ShortTenn Notes Payable 0
Current Portion of LT Debt 0
Other Current Liabilites 0
LongTerm Debt 0
Other Non-CurrentLiabilites 0
Excess/Non-OperatingAssets 0
Indicated Equity Value 748,562

SELECTED
EQUITYVALUE 748,600

9

DLH.SF-002864
FARMER, FUQUA & HUFF P.C.
.,ncl < 1111,11ft,1111,
\1 t n,1111.1111,
Fif
·..:'I" l (•I'll, 1,11\ ',1 ·,
~~••I Jrdi..,tp 1,•,.1, -;,1., >
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ri
Personal Goodwill Calculation

Importance Importance Weighted Weighted
Factor Score Weight Entity Component % Personal Component % Total Entity% Personal%
Operations 1.0 6.7% Systems and Processes 100% 0% 100% 6.7% 0.0%

Trade name and marketing assets 1.0 6.7% Business name 0% Personal business name 100% 100% 0.0% 6.7%

Location & Facilities 0.0 0.0% Business location(s) 0% 0% 0% 0% 0%

Protective & Required contracts 0.0 0.0% Franchise, license, territory, payor, vendor, 0% 0% 0% 0% 0%
etc.
Intellectual Property 1.0 6.7% Business IP 100% Personal IP 0% 100% 6.7% 0.0%

Reputation 2.0 13.3% Business reputation 25% Personal reputation 75% 100% 3.3% 10.0%
Contract & recurring revenues 1.0 6.7% Customer contracts, customer relationships 51% Personal customer relationships 49% 100% 3.4% 3.3%

Workforce 0.0 0.0% Workforce 0% Work habits 0% 0% 0% 0%

Business development 3.0 20% Salespersons and company marketing efforts 0% Personal referrals and marketing 100% 100% 0.0% 20%
efforts
Employment agreements 3.0 20% Presence of agreements 0% Absence of agreements 100% 100% 0.0% 20%

Skills & abilities 3.0 20% Other employee's skills abilities 0% Personal skills abilities 100% 100% 0.0% 20%

Total 15.0 100.0% 20% 80%

10

DLH.SF-002865
FARMER,FUQUA & HUFF P.C.
\( ( '111111,//1/, ,Ille/ ( 1111,uft,111/,

'-:' '- C f•J'U f ,t•\ '•l t J( 1 "1--f ,- \ if l
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Valuation Assumptions

1. Market Approach: Comparable Transaction Method (Bizcomps)

Dwight Hill Insurance Agency Inc. is a Property and Casualty Insurance Agency. Since Property and Casualty Insurance
Agencies are typically more profitable than other Insurance Agencies in general, the Valuator selected the 65 th Percentile
transaction multiple from the selected comparable transactions.

2. The Valuator opines that 80% of the success of Dwight Hill Insurance Agency Inc. is attributable to Mr. Dwight Hill's skills,
abilities, and reputation. In this light, the Valuator selected an 80% Personal Goodwill Discount in the Valuation of Dwight Hill
Insurance Agency, Inc.

11

DLH.SF-002866
EXHIBITG

RESTORE AGREEMENT -
COMMUNITY JOINT
VENTURE
- --·•--· -------

- ·•• -·-- --·---------

-------
•• -·--·---
1- 7 -/ 7
----....-, ---·-··----.

-- • -----
=.:,..1· 7=2·=;;;:i.--7~_-
.9_"'--=•- --· I

- - ________
____
......
,..., ____ ._,,_;..._.......-1
"l

·--· ···-·-·-------·- ----------
w
EXHIBITH

· DHIA ARTICLES OF
INCORPORATION
•
FILED
In the Office of the
Secretaryof State of Texag
ARTICLES OF INCORPORATION
OF 18 2002
MAR
DWIGHT
HILL INSURANCE INC.
AGf::NCY, Section
Corporations

ARTICLE I
~

The name of the corporation is Dwight Hill Insurance
Agency, Inc.

ARTICLE II
DURATION
The period of duration is perpetual.

ARTICLE III
PURPOSE
The purpose for which the corporation is organized is the
transaction of any and all lawful business for which corporations
may be .incorporated under the Texas Business Corporation Act.

ARTICLE:IV
CAPITA.L STRUCTURE

The aggregate number of shares which the corporation
shall have authority to issue is ONE MILLION (1,000,000) of the par
value of ONE CENT ($.01) each.

ARTICLE V
COMMENCEMENT
OF BUSINESS
The corporation will not commence business until it has
received for the issuance of its shares consideration of the value
of ONE THOUSANDDOLLARS($1,000), consisting of money, labor done
or property actually received.

ARTICLE VI
BOARD
Of DIRECTORS
The number of directors ccnstituting the initial.ooard ofl
.t. . · · ·. I
directors of the corporation is one (1), and the name and adtiress• •
of the person who is to serve as director until the first annual

EXHIBIT DLH-000095

w 1r
Produced 11.30.2022
•
... . .
meeting of the shareholders or until his successor is elected and
qualified is:
Mr. Dwight L. Hill
10222 Midway Road
Dallas, Texas 75229

ARTICLEVII
REGISTERED
OFFICE1\NP .AGEN:f
The street address of the corporation's initial
registered office is 10222 Midway Road, Dallas, Texas 75229, and
the name of its initial registered agent is Dwight L. Hill.

ARTICLE VIII
INCORPORATQRS
The name and address of the incorporator is:
Mr. Dwight L. Hill
10222 Midway Rd.
Dallas, Texas 75229
DATED: March 8, 2002.

~},/411
ght L. Hill

DLH-00009&
Produced 11.30.2022
EXHIBIT I

Note showing Respondent as
Vice President of DHIA
. . . 1LoanApplication .• ,
Un1fonnRes1dent1a . •· .. . •... ,.-~- lr-••, -

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EXHIBIT J

DHIA/STATE FARM
CONTRACT
. I. M4{1NC)(TX)

,l tl -'-1-3
STATEFARMAGENT'SAGREEMENT

State Fann Mutual AutomobileInsurance Company,State Fann Life InsuranceCompany, State Farm Fire and Casualty

Company, and State Fann General Insurance Company,collectivelyreferred to in this Agreementas 11State Farm/ or "the

Companies,11 insurancecorporationsorganizedand existingunderthe lawsof the Stateoflllinois,withtheirprincipalofficeslocatedat

Bloomington,Illinois,and StateFann CountyMutualInsuranceCompanyofTexas, an insurancecorporationorganizedand existing

under the laws of the State of Texas with its principal office located at Dallas, Texas, appoint DWIGHTHILL INSURANCE

AGENCY,INC.,a corporationorganizedand existingunderthe lawsof the Stateof Texas,withitsofficelocatedat, Texasreferredto

in this Agreementas ,.theAgent,"to representthe Companiesin Texas, while properly licensedso to act, in accordancewith the

provisionsof this Agreement. The chief executiveofficerof the Agent shall be the President. Scheduleof PaymentsFormsAS4,

CMS2,FS3,OS2,HSS,LLS1,LSSa,and LS8 applicableto the respectivecompanyas indicated,heretoattached,constitutea part of

this Agreement.This Agreementis to becomeeffectiveAugust I, 2002, and shall continueuntil tenninatedas hereinprovided.

officersand licensedsalesrepresentativeswillalso be invited
PREAMBLE to attend meetings conducted by the Companies for the
purpose of introducingnew products, ideas, services and
The purposeof this Agreementis to reduceto writingthe procedures,promotingsales,andprovideassistance,·guidance,
objectives,obligations,and responsibilitiesessentialto the and consultationto better enable the Agent to cany out the
relationshipbetween the Corporate Agen~ its officers and provisionsof this Agreement.
employees,and State Farm. It is to our mutual interestto
satisfactorilyserve the insuring public, to comply with all The Companiesand the Agentexpectthatbyenteringinto
applicablelaws,to increasebusinesscommensuratewith the this Agreement,and by the full and faithfulobservanceand
availablepotential,and to maintainthe Companies'operations perfonnanceof the obligationsand responsibilitieshereinset
on a profitablebasis in orderto assurethe necessaryfinancial forth,a mutuaJlysatisfactoryrelationshipwill be established
strengthto protectthe policyholders'interest. and maintained.

Insuranceis a closelyregulatedbusiness.TheCompanies To these ends, the Companies, the Agent and the
and the agents must deal equitablywith policyholdersas to Presidentagree that:
rates and claims, be trustworthyin handling money, avoid
false advertisingand unfair practices,and refrain from any
action that would result in violation, by State Fann or any SECTION I - MUTUALCONDITIONS AND DUTIES
agent, of any applicablelaw or regulation.
A. The Agentwill solicitapplicationsfor insurance,coJlect
The Companiesdo not seek and will not assert control initial premiums, membership fees and charges,
over the Agent'sofficersor licensedsales representatives,but countersignand deliver policies, reinstate and transfer
expect them to exercise their own judgment as to the time, insurance, assist policyholders and cooperate with
place, and manner of soliciting insurance, servicing adjustersin reportingand handlingclaims,avoidconflicts
policyholders,and otherwisecarrying out the provisionsof of interest,and cooperatewith and advancethe interests
this Agreement. of the Companies,their agents,and the policyholders.

State Fann will make available to the Agent the B. The Officers and licensed sales representativesof the
experienceand technicalknowledgeacquiredand developed Agenthavefull controlovertheirdailyactivities,withthe
over the years in respect with sellingyunderwriting,and right to exerciseindependentjudgmentas to time, place,
servicinginsurance. The Companieswill designatespecific and manner of soliciting insurance, servicing
employeesof the Companiesto guide and advisethe Agent's policyholders,and otherwisecarryingout the provisions
officers and licensed sales representatives. The Agent's of this Agreement.
policyholder resides within a 25-mile radius of th8\_
C. State Fann will furnish the Agent, without charge, Agent's principal place of business and within a state in •
m8Jluals, fonns, records, and such other materials and which the Agent is duly licensed, except that the
supplies as the Companies may deem advisable to Companies may, after prior written notice to the Agent,
provide. All such property furnished by the Companies transfer any automobile policy to the account of another
shall remain the property of the Companies. In addition, State Farm agent when the policyholder makes a bona
the Companies will offer at the Agent's expense such fide request in writing. The Agent will respect the rights
additional materials and supplies as the Companies feel and interests of other agents in policies credited to their
may be helpful to the Agent. accounts by refraining from raiding or otherwise
diverting policies ftom their accounts to the Agent's
D. . Infonnation regarding names, addresses, and ages of account.
policyholders of the Companies; the description and
location of insured property; and expiration or renewal I. AUmoneys collected on behalf of the Companiesshall be
dates of State Fann policies acquired or coming into the held in trust by the Agent as the absolute property of the
Agent's possession during the effective period of this Companies, and the Agent will be responsible for these
Agreement, or any prior agreement, except infonnation moneys until they are safely transmitted to the
and records of policyholders insured by the Companies Companies. The Agent agrees to maintain in a bank or
pursuant to any governmental or inSllranceindustry plan similar financial institution, a premium fund account,
or facility, are trade secrets wholly owned by the which the Companies may audit at any time, in which the
Companies. All forms and other materials; whether Agent will promptly deposit all cash collected for
furnished by State Fann or purchased by the Agent, upon premiums, membership fees, and charges. The Agent
which this information is recorded shall be the sole and further agrees to transmit promptly to the Companies the
exclusive property of the Companies. moneys so deposited, through checks drawn upon this
premium fund account, along with all insurance
~- The expense of any office, including rental, furniture,and applications received and all checks collected on behalf
,: . equipment; signs; supplies not furnished by the of the Companies.
Companies; the salaries of the Agent's employees;
telegraph; telephone; postage; advertising; and all other J. Any amount (exclusive of premiums due on policies
charges or expense incurred by the Agent in the issued to the Agent and the President) at any time owing
performance of this Agreement shall be incurred by the by the Agent to any of the Companies, their subsidiaries
Agent at the Agent's discretion and paid by the Agent and affiliates, shall be a first lien on any payment due or
We anticipate that in the location or relocation of the thereafter becoming due the Agent under any of the
Agent's office there will be no undue infringement on the provisions of this Agreement, and the Companies are
established office location of any other agent. The Agent authorized to deduct such indebtedness from any such
will not establish any office in addition to the Agent's payment due or thereafter becoming due to the Agent
principal office without the prior written approval of the from any of the Companies.
Companies.
K. If any application is rejected or any policy is surrendered
F. The Companies will advertise, provide promotional or cancelled, in whole or in part, for any reason, before
materials, and participate in the cost of the Agent's the expiration of the policy period, or if any premium is
advertisements in accordance with policies determined reduced or any overpayment made to the Agent, the
from time to time by the Companies. The Agent will not compensation paid to the Agent on the amount returned
use any advertisements referring to or identifying the or credited to the policyholder or the amount overpaid to
Companies in any way without the prior written approval the Agent shall be charged to the Agent and shall
of the Companies. constitute an indebtedness of the Agent to the Companies.

G. The Agent shall provide at least one licensed sales L. The Companies retain the right to prescribe all policy
representative whose principal occupation will be the fonns and provisions; premiums, fees, and charges for
fulfillment of the Agent's obligations established by this insurance; and rules governing the binding, acceptance,
Agreement. The fulfillment of the Agreement shall be renewal, rejection, or cancetJation of risks, and
the Agent's principal business and neither the Agent nor adjustment and payment of losses.
any licensed sales representative employed by the Agent
will directly or indirectly write or service insurante for M. The Agent will not represent itself as having any powers
any other Company, other than a State Fann subsidiaryor except those authorized by this Agreement,and subject to
affiliate or through any governmental or insurance any applicable law. Without limiting the foregoing, the
industry plan or facility, or for any agent or broker, Agent shall not have authority to extend the time of
extept in accordance with the terms of any written payment of any premium, or to alter, waive, or forfeit any
consent the Companies may give the Agent. of the Companies' rights, requirements, or conditions in
any policy of insurance, or otherwise obligate the
H. The Companies will leave in the Agent's account all Companies in any way except as stated in this Agreement
automobile policies credited thereto so long as the or expressly authorized under the rules and regulationsof
/ the Companiesor as otherwiseauthorizedin writingby insurance coverage competitive with the insurance
the Companies. coverages sold by the Companies. In the event the
"period of one year" conflicts with any statutory
provision,such period shall be the period pennitted by
SECTION11-COMPENSATION statute.

A. Each Companywill make paymentsto the Agent as set
forth in the applicableScheduleof Payments. SECTIONIV - TERMINATIONPAYMENTS

B. As additional compensation,State Fann will maintain A. In the event this Agreementis terminated,the respective
insuranceupon the life of the President,payableto the Companieswill, subject to the conditions set forth in
beneficiary selected by the Agent, so long as this subparagraphA·S and paragraphB of this section, pay
Agreementhas not been terminatedand the Presidenthas the Agent, less any deductions for commissioncharge
not attainedage 65; provided,however,that in no event backs,the followingterminationpayments:
will suchinsurancebe maintainedin forceduringa period
commencingthirty-onedaysafterthe Presidenthas begun 1. STATE FARM MUTUAL AUTOMOBILE
active duty as a member of the military, naval, or air INSURANCECOMPANYwill pay;
forces of any country or internationalorganizationand
ending with terminationof such duty. The amount of (a) For the first twelve (12) months followingthe
insuranceduring any calendaryear shaJIbe equalto the date of terminationthe lesser of the amounts
Agent'sgrosscompensationreceivedfromtheCompanies computedin ( l) and (2): •
in the precedingcalendaryear,exclusiveof compensation
based on policies issuedby the Companiespursuantto ( 1} twenty percent (20%) of the service
any governmentalor insurance industry plan, pool or compensation on "personally produced"
facility, or $10,000,whicheveris the greater, but in no policies by the licensed sales
event shall such insurancebe more than $50,000. representative(s)designatedby the Agent
pursuantto SectionVLA(3),earned under
C. EachCompanyreservesthe rightto fix and determinethe the Scheduleof PaymentsFor Other Than
amount,extent, and conditionsof any bonuses,awards, HealthInsurancePoliciesin the twelve(12)
prizes,and allowances. precedingmonths,Q.rtwentypercent(20%)
of the servicecompensationon "personally
produced"policies creditedto the Agent's
SECTIONIll - TERMINATIONOF AGREEMENT account, as of the date of termination,
which remain in force in the same state
A. The Agentor State Farmhave the right to tenninate this during the first twelve ( 12) months
Agreementby written notice delivered to the other or following the date of termination,
mailed to the other's last known address. The date of whicheveris greater,or
tenninationshallbe the date specifiedin the notice,but in
the eventno date is specified,the dateof terminationshall (2) thirty percent (30%) of the service
be the date of delivery if the notice is mailed. Either compensation on "personally produced 11

party can acceleratethe date of the tenninationspecified policies creditedto the Agent'saccountas
by the other by giving written notice of terminationin of the date of termination,which remainin
accordancewith this paragraph. force in the same state during the first
twelve (12) months followingthe date of
B. Afterterminationof thisAgreement,theAgentagreesnot termination.
to act or represent itself in any way as an agent or
representativeof the Companies. In the event thirty percent(30%)of the service
compensationas specifiedin (2) is Jessthan the
C. Withinten days after the terminationof this Agreement, greater amountof the servicecompensationas
all propenybelongingto the Companiesshallbereturned computed in ()) and if the number of such
or made available for return to the Companiesor their "personallyproduced" policies in force at the
authori1.edrepresentative. end of the firsttwelve( 12)monthsfollowingthe
date of terminationis equal to or greater than
D. For a period of one year followingterminationof this seventy-fivepercent(75%)of thenumberof the
Agreement,neither the Agent, the President,nor any of "personallyproduced"policiesin force at date
the licensedsalesrepresentatives,willeitherpersonallyor of termination, the Agent will be paid the
through any other person, agency, or organization(a) amountprovidedfor in (1).
induceor adviseany StateFann policyholdercreditedto
the Agent'saccount at the date of tennination to lapse, (b) For the first twelve (12) months followingthe
surrender,or cancelany StateFarminsurancecoverageor date of terminationthe lesser of the amounts
(b) solicit any such policyholder to purchase any computedin (1) and (2):
(1) twenty percent (20%) of the service
compensation the Agent earned on health
(d) For each of the succeeding forty-eight (48)
months the Agent will be paid an amount equal
'
insurance policies under the Schedule of to one-twelfth (I/12th) of the total amount
Payments For Health Insurance Policies in payable in the first twelve ( 12) months after
the twelve (12) preceding months, .Q! termination.
twenty percent (20%) of the service
compensation on health insurance policies 2. STATE FARM FIRE AND CASUALTY
credited to the Agent's account at date of COMPANY, STATE FARM GENERAL
tennination which remain in the same state INSURANCE COMPANY and STATE FARM
and in force during the first twelve months COUNTY MUTUALINSURANCECOMPANYOF
following the date of tennination, except TEXAS each will pay:
those policies which became available in
the same state for assignment to an agent as (a) For the first twelve (12) months following date
a result of the tennination of an agreement of tennination the lesser of the amounts
between the Company and an agent, or as a computed in (1) and (2):
result of an agreement between an agent
and the Companies pursuant to the (I) twenty percent (20%) of the commissions
applicable paragraph of Section IV of a the Agent was paid on "personally
State Fann Agent's Agreement, on which produced" policies by the licensed sales
one year has not elapsed since date of representative(s) designated by th~ Agent
tennination; whichever is greater, Qr pursuantto Section VI.A(3), for those lines
of insurance classified by the Companies in
(2) two percent (2%) of the second and paragraphs 1-A, Band C of the applicable
subsequent policy years net premium Schedule of Payments, in the twelve (12)
·'.
collections received and recorded in the preceding months, m: twenty percent (20%)
twelve (12) months following date of of the commissions on such ..personally
tennination on health insurance policies produced" renewal premiums, which would
which remain in the same state, credited to have been paid under the applicable
the Agent's account as of the date of Schedule of Payments, if this Agreement
tennination, except those policies which had not been tenninated, in the twelve (12)
became available in the same state for months following the date of terminationon
assignment to an agent as a result of the such "personally produced11 policies, which
termination of an agreement between the remain in the same state, for those lines of
Company and an agent, or as a result of an insurance designated above and credited to
agreement between an agent and the the Agent's account as of the date of
Companies pursuant to the applicable tennination; whichever is greater, or
paragraph of Section IV of a State Fann
Agent's Agreement, on which one year has (2) thirty percent (30%) of the commissions on
not elapsed since date of termination. such 11personally produced" renewal
premiums which would have been paid
In the event two percent (2%) of the net under the applicable Schedule of Payments,
premium collections as specified in (2) is Jess if this Agreement had not been tenninated,
than the greater amount of the service in the twelve (12) months following the
compensation as computed in (1) and if the date of tennination on those "personaJly
number of policies in force at the end of the first produced11 policies designated in (1) and
twelve ( 12) months following the date of credited to the Agent's account as of the
tennination is equal to or greater than seventy- date of termination.
five percent (75%) of the number of policies in
force at date of termination, the Agent will be lo the event thirty percent (30%) of the
paid the amount computed in (1 ). commissions as computed in (2) is less than the
greater amount computed in (1) and if the
(c) The payments provided for in (a) and (b) shall number of such designated "personally
be made in estimated monthly installmentsequal produced11 policies in force at the end of the first
to twenty percent (20%) of the service twelve (12) months following date of
compensation earned in the twelfth ( 12th) t~nnination is equal to or greater than seventy-
preceding month subject to appropriate five percent {75%) of the number of such
adjustments following a detennination of the net designated "personally produced" policies in
premium collections as specified in {a)(2) and force at date of tennination, the Agent wiJI be
(b)(2) and the number of policies in force, where paid the amount provided for in (I).
applicable.
~ ..
;e,-/'•A,.'l'i..•
...... \ .
,
(b) The payments provided for in (a) shaJI be made • (c) On Flexible Premium Retirement policies in the
in estimated monthly installments equal to Agent's account on which the Agent is eligible
twenty percent (20%) of the commissions paid for servicing compensation at the time of
on the designated "personallyproduced0 policies tennination of this Agreement, an amount equal
in the twelfth (12th) preceding month subject to to three-fourths of one percent (3/4 of 1%) of an
appropriate adjustments following a average monthly premium of the policies shall
detennination of the commissions specified in be paid in monthly installments for each of the
(a)(2) and the number of such "personally ,... sixty (60) months after tennination of this
produced" policies in force, where applicable. Agreement, except that no amount shall be paid
on those policies made available for assignment
(c) For each of the succeeding forty-eight (48) by the tennination of an agreement between the
months the Agent will be paid an amount equal Company and an agent or by a release of
to one-twelfth (1112th) of the total amount policies pursuant to the applicable paragraph of
payable in the first twelve (12) months after Section JV of a State Fann Agent's Agre~ment
tennination. The average monthly premium of a policy shall
be calculated by dividing the total premium paid
3. STATE FARM LIFE INSURANCE COMPANY on the policy by the number of full months
will pay on business written before January 1, 1982: elapsing between its Policy Date and tennination
of this Agreement.
(a) An amount equal to the same compensation, for
the second and subsequent policy years as would 5. GOVERNMENTALOR INSURANCEINDUSTRY
have been due and payable to the Agent for the PLAN OR FACILITY. All policies, premium
first five years following the date of tennination collections and compensation the Agent receives
on all State Fann life policies personally written thereon, issued by the Companies pursuant to any
by the licensed sales representative designated governmental or insurance industry plan or facility,
by the Agent pursuant to Section VI.A(3), or shall be excluded from the calculations and
assigned to the Agent by the Company for provisions for tennination payments.
compensation, under the tenns of the applicable
Schedule of Payments attached hereto, if this 6. CESSATION OF BUSINESS. ln the event the
Agreement had not been tenninated. respective Company discontinues doing business in
the state in which the agent is licensed as a
(b) The payments provided for in (a) shall be made representative of the Company, that Company agrees
in monthly installments for each of the sixty to pay the agent the following payments in lieu of the
(60) months which would have been due and tennination payments provided for in this section and
payable to the Agent for that month if this Section V of this Agreement, subject to the mutuaJ
Agreement had not been tenninated. conditions herein set forth:

4. STATE FARM LIFE INSURANCE COMPANY (a) For the first twelve (12) months following the
wilJ pay on business written during the existence of date of tennination STATE FARM MUTUAL
this Agreement and on or after January I, 1982: AUTOMOBILEINSURANCECOMPANY will
pay the amount computed in A· 1 based on your
(a) On life policies personally written by the earnings under the applicable Schedule of
licensed sales representative designated by the Payments in the twelve (12) preceding months
Agent pursuant to Section VI.A(3), an amount as provided for in A-1-(aXJ) and A-1-(bXI).
equal to the writing compensation, for the
second and subsequent policy years as would (b) For the first twelve (12) months following the
have been due and payable to the Agent under date of tennination STATE FARM FIRE AND
the tenns of the applicable Schedule of CASUALTY COMPANY, STATE FARM
Payments attached hereto if the Agreement had GENERAL INSURANCE COMPANYt and
not been tenninated. STATE FARM COUNTY MUTIJAL
INSURANCE COMPANY OF TEXAS will pay
(b) On life policies in the Agent's account on which the amount computed in A-2 based on the
two percent (2%) servicing compensation is commissions you were paid under the applicable
being paid to the Agent at the time of Schedule of Payments in the twelve (12)
tennination of this Agreement, an amount equal preceding months as provided for in A-2-(a)( l ).
to one and one-half percent (l 112%)of one- (c) For each of the succeeding forty-eight (48)
twelfth (1/12) of the annuaJized premium of the months you will be paid by that Company an
policies shall be paid in monthly installmentsfor amount equal to one-twelfth ( 1112th) of the
each of the sixty (60) months after termination amount payable in the first twelve (12) months
of this Agreement after tennination.

DLIMIOOI09
(d) The foregoing payments are to be made only on (2) the President was a licensed agent for th'\
your written acceptance of a tennination date to ~: Companies, or a licensed sales representative of the
be determined by the applicable Company. Agent, for a combined period of twenty (20) years or
more, either under this Agreement or accumulatively
(e) In the event of your written acceptance as under any prior State Fann Agent's Agreement
provided for in (d) the app)icable Company (Form AA) or Local Agent's Appoinbnent (Form
agrees to transfer to you all its rights and LA); and
ownership in the property set forth in paragraph
D of Section 1 of this Agreement. (3) the President had ten (JO) years of combined
continuous service as a licensed agent for the
8.. Payments under paragraph A above shall be as follows: Companies, or a licensed sales representative of the
Agent, immediately preceding the date this
1. If within ten (JO) days following the date of Agreement is terminated;
termination, all property belonging to the respective
Companies has been returned or made available for the respective Companies will pay the Agent monthly
return to that Company or its authorized payments beginning on the last day of the 61st month
representative the Agent shall qualify for the first following termination and continuing until the last day of
two (2) monthly installments from that Company as the month in which the death of the President occurs,
provided in paragraph A. either

2. If the Agent has qualified for payments by the if the President is 65 years of age or older at
respective Companies under subparagraph B-1, and termination of this Agreement, an amount equal to
so long as the Agent, the President, and the licensed the following,
sales representative, have not, for a period of twelve
(12) months following tennination of this or
Agreement, either personally or through any other
person, agency or organization. solicited or sold, if the President is 62, 63, or 64 years of age at
either at renewal time or otherwise, to that tennination of this Agreement, a lesser amount based
Company's policyholders, which were credited to the on the following adjusted by an actuarial equivalent
Agent's account at the time of termination, any factor based upon the President's age at termination
insurance coverage competitive with the insurance of this Agreement:
coverages sold by that Company, the Agent shall
qualify for the remaining monthly installments from l. STATE FARM MUTUAL AUTOMOBILE
that Company as provided in paragraph A. INSURANCE COMPANY will pay an amount equal
to the monthly payment by this Company as
C. ln the event the Agent and the Company enter into a provided for in subparagraph A-1-(a) of Section IV.
written agreement, without the complete termination of
this Agreement, to release at one time from the Agent's 2. STATE FARM FIRE AND CASUALTY
account for reassignment to other agents, at least twenty- COMPANY, STATE FARM GENERAL
five percent (25%) or five hundred (500), whichever rNSURANCE COMPANY and STATE FARM
number is Jess, of the automobile insurance policies COUNTYMUTIJAL INSURANCECOMPANY OF
credited to the Agent's account, and in addition al] other TEXAS will pay amounts equal to the following:
State Fann policies held by policy-holders and members
of the households of such policyholders whose (a) That portion of the monthly payments by these
automobile insurance policies are reassigned, the Companies as provided for in subparagraph A-2
Companies with respect to the policies so released, will of Section IV based on ''personal lines of
pay the Agent the tennination payments in accordance insurance" so classified by the Companies in the
with the provisions of paragraphs A and B, as those applicable Schedule of Payments; and
provisions may be applicable to each of the Companies.
(b) 50% of that portion of the monthly payments by
SECTIONV • EXTENDEDTERMINATION these Companies as provided for in
PAYMENTS subparagraph A-2 of Section IV based on the
"commercial lines of insurance" so classified by
A. In the event the Agreement is terminated, and the Agent the Companies in the applicable Schedule of
qualified for the termination payments set forth in Section Payments. Provided, however, that these
IV-B-1 and 2, and at the time of tennination of this payments on such 11commercial Jines of
Agreement: insurance" shall be calculated on only the first
$5,000.00 of net premium collections received
( J) the President of the Agent is 62 years of age or by the Companies on any one risk or policy.
older; and
·,I . I. . .
,I •

.r 3. STATE FARM LIFE INSURANCE COMPANY
will pay an amount equal to the monthly payment by ' C. Each Company shaU be bound by all the terms of this
this Company as provided for in subparagraphs A-4- Agreement, except that the separate Schedule of
(b) and (c) of Section IV. Payments hereto attached, and those other provisions
where the express language or context indicates that they
are applicable to the individual Companies only; and the
SECTIONV1- GENERALPROVISIONS rights and duties of the Agent with respect to each
Company shall be governed accordingly.
A. This Agreement has been entered into by the Companies
with the Agent in reliance upon the representations and D. The President in his individual capacity shall be bound
agreements that: only by the tenns of this Agreement that specifically refer
to the President.
(1) The following person(s) substantially participate(s)
in the ownership of the Agent: E. All payments for tennination which otherwise might have
become available to the Agent under the tenns of prior
PERCENTAGE OF agreements with any of the Companies are hereby waived
NAME ADDRESS INTEREST by the Agent.

Dwight L. Hill 10222 Midway Rd. 100 F. This Agreement shaU supersede all prior agreements
Dallas, TX 75229-6231 between the parties hereto, written or otherwise, and it
shall constitute the sole and entire Agreement between the
(2) The President of the Agent, having full managerial parties, and no change, 'alteration, or modification of the
authority and responsibility for the operating terms of this Agreement may be made except by
management of the Agent as provided for by its by- agreement in writing signed by a Regional Vice President
laws, shall be a person acceptable to the Companies. or an Agency Vice President of the Companies and
The Agent will advise the Companies, in writing, at accepted by the Agent.
least fony-five (4S) days prior to the appointment of
such President of the identities and qualifications of
all candidates being considered for appointment as
President. The Companies will be deemed to have
approved those candidates with respect to which they
have not notified the Agent of their unacceptability
within thirty (30) days after receipt of the Agent's
advice that the candidates are being considered for
appointment.

(3) The person or persons designated by the Agent as
licensed sales representative(s) of the Agent shall be
acceptable to the Companies. The Agent will advise
the Companies, in writing, at leasefony-five (45)
days prior to appointment of a licensed sales
representative of the identities and qualifications of
all candidates being considered for appointment as
licensed sales representative(s). Unless the
Companies, within thirty (30) days after receipt of
such advice, notify the Agent that a candidate is
unacceptable to the Companies, the Companies will
be deemed to have approved such candidates.

AU notices of the identities and qualifications of
candidates for the position of President or licensed
saJes representative shall be sent to a Regional Vice
President or Agency Vice President.

B. Since each party is relying upon the other or others to
carry out the provisions of this Agreement, neither the
Agreement nor any interest thereunder can be sold,
assigned, or pledged; and no right in any sum due or to
become due to the Agent hereunder can be sold, assigned,
or pledged without the prior written consent of the
Companies.

Cl~11
i
IN WITNESSWHEREOF,the parties havecausedthis Agreementto be executedin triplicateon their behalfs. '·
--1

DWIGHTHILL INSURANCEAGENCY,INC.

By:___ ~-ift-N-',-iden-t ~ 2----•-M--i.--
ZL-' 2. /41!1'
DwightL. &ually

STATEFARMMUTUALAUTOMOBILEINSURANCECOMPANY
STATE FARMLIFE INSURANCECOMPANY
STATE FARMFIRE AND CASUALTY COMPANY
STATE FARMGENERALINSURANCECOMPANY
_ ~ . STATEFA COUNTYMUTUALINSURANCECOMPANYOF TEXAS

~~ A
By:_~~---+1----A_u_th_o_riz ...ed,_;,_It~ep...:re~s-en..;..ta..;.t1-·v~,-,:;--
ce President
of gency

KRIST\ROTH
oS 2002
1->:UG

(Rev. l/1/81) Pl'inttd In U.S.A.
•.. : ' . .-
•

MEMORANDUMOF AGREEMENT

(STATEFARMAGENT'SAGREEMENT- CORP.FORMAA4)

MEMORANDUMOF AGREEMENTby and betweenSTATEFARMMUTUALAUTOMOBILEINSURANCE
COMPANY,STATE FARMFIREANDCASUALTY COMPANY,STATE FARMLIFEINSURANCECOMPANY,
STATE FARM GENERALINSURANCECOMPANY,and STATE FARM COUNTY MUTUALINSURANCE
COMPANYOF TEXAS,hereinafterreferredto as the "Companies",and DWIGHTHILL INSURANCEAGENCY,
INC., and DwightL. Hill, individually,hereinafterreferred to as the "Agent".

WHEREAS,the Companiesenteredinto an agreementwith DwightL. Hill effectivethe 1stday of August, 1990,
knownas the STATEFARMAGENTS AGREEMENT,Fonn AA4(TX-1);and,

WHEREAS,the agent decided to tenninate his STATE FARMAGENT'SAGREEMENTeffectivethe 31st day
of July, 2002; and executethe CorporateAgencyAgreementeffectivethe 1stday of August,2002; and

WHEREAS,the CorporateAgencyreceivedno compensationduringcalendaryear; and

WHEREAS,the Companiesas a matterof policywiUnot enter into a contractwith a CorporateAgencyownedin
whole or in part by an individualagent if the transactionwould result in a substantialpayment being made to the
individualagent upon tenninationof the individualagent's contract;

NOW THEREFOREnus AGREEMENTWITNESSETHAS FOLLOWS:

1. Subjectto the other provisionsof SectionII, ParagraphB of the CorporateAgencyAgreement,it is agreedthat
the amountof insuranceprovidedunder this section during2002 shall be the sum of the gross compensation
receivedas an individualagent,exclusiveof compensationbasedon policiesissuedby the Companiespursuant
to any governmentalor insuranceindustry plan, pool or facility, during 2001, but in no event shall such
insurancebe more than SS0,000.Duringthe year of2003 the amountof insuranceshallbe the sumof the gr<>§
compensationreceived as an individualagent, exclusive of compensationbased on policies issued by the
Companiespursuantto any governmentalor insuranceindustryplan, pool or facility,during 2002, and the
Corporation'sgross compensation,exclusive of compensationbased on policies issued by the Companies
pursuantto any governmentalor insuranceindustryplan,poolor facility,receivedduring2002,but in no event
shall such insurancebe more than $50,000. During the year of 2004 and thereafter the provisionsin the
CorporateAgencyAgreementitself shall govern the amountof insurance.

2. Since the transfer of an individualagency into a CorporateAgency does not constitutetennination of an
individualagency contract within the meaning of the original contract, it is hereby mutually agreed and
understood that all payments set forth in Section IV of the STATE FARM AGENT'S AGREEMENT
heretofore in existencebetween the Companiesand Dwight L. Hill which otherwise might have become
payableto DwightL. Hill under the tenns of such SectionJV are herebywaived by DwightL Hill.

3. In the event the CorporateAgency Agreementis terminatedprior to the Agreementbeing in force at least
twelve( 12)precedingmonths,the computationsfor tenninationpaymentsbasedon thatportionof the fonnula
with respectto earnedservicecompensationin the twelve(12) precedingmonthspursuantto subparagraphA-
1-(a)(1) and A-l(b)(l) of Section IV, and with respect to paid commissionsin the twelve (12) preceding
months pursuant to subparagraphA-2-(a)()) of Section IV, shall be interpretedto include the months the
licensed sales representative(s)was representingthe Companiesunder an individualState Fann Agent's
Agreement.

4. The foregoingagreementshall be effectiveas of the effectivedate of the CorporateFonn of Agreement.
'\ .

-z..
"lday
IN WJ~e
- u O
parties hereto have executed this MEMORANDUM OF AGREEMENT this
7.,0~ ?....

STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY
STATE FARM FIRE AND CASUALTY COMPANY
STATE FARM LIFE INSURANCE COMPANY
STATE FARM GENERAL INSURANCE COMPANY
STATE COUNTY MUTUAL INSURANCE COMPANY OF TEXAS

WITNESS:

exas Operation C

WITNESS:

ioJi,1. G__LJ._ Qf l,~~

WITNESS: A~.2./Lc$
~w_~~
Dwight L. J,lndMdually

KRISTI
ROTH
AUGO5 2002
43·77/1

AA4(1NC)(TX)

AUTHORIZATION
(DEDUCTIONSFROM EARNINGS)

DWIGHTHILL INSURANCEAGENCY,INC., a corporationorganizedand existingunderthe lawsof the State of
Texas, does hereby authorize the State Fann Insurance Companies to deduct from its earnings the same monthly
deductions which were made from Dwight L. Hill's earnings prior to incorporation,and furtherauthorize and ratify all
future deductions from said earnings. Said authorizationshall become effectiveconcomitantlywith the effectivedate of
the AA4 CorporateForm, and shall remain in fu]l force and effect while said corporationis properlylicensedto act as an
agent for the State Fann Insurance Companies unless otherwise directed by the President of the Corporation.

Oated_____ 7....._,/._z_7
__ 0_2-

WITNESS: By: Dr,:.M-~-lt/41'
Pre:tident
Ron-,
l<Fl1S71
AUG0 5 2002

DUMIGGIH
EXHIBITK

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Shareholder's Share of Income, Deductions,
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tffliH!ibMInformationAboutthe Corporation ~ 4----r.-
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1-----------------------1
A Corporation·semployeridentificationnumber
i--::~~~--------~- --------------
XX-XXXXXXX 5 a Ordinarydividends
• B Corporation'sname,address,c,ty, state. and ZIP code
DWIGHT HILL INSURANCE
AGENCY INC 5 b Qualifieddividends 14 Foreigntransactions
10300 N CENTRALEXPYSTE 296
DALLAS,TX 75231 r"".:~=--~--------+-
6 Royalties
- -~- - - - - - - - - - - - - -

~~~----------1--- --------------
7 Net short-termcapitalgain (loss)
C IRSCenterwherecorporationfiled return
E-FILE ~~:'":""""."~--------+---~--------------
8 a Net long-termcapitalgain (loss)

11Ralllll$:1
InformationAbout the Shareholder t---t-~---------+-
8 b Collectibles(28%)gain (loss)
- - - - - - - - - - - - - - - -

D Shareholder'sidentifyingnumber
t---+-:------------1--· --------------
XXX-XX-XXXX 8 c Unrecapturedsection 1250gain
E Shareholder'sname,address,cily, state, andZIP code
t----t-----------+-- --------------
MARIBEL L HILL 9 Net section 1231gain (loss)
4246 W LOVERSLN
DALLAS,TX 75209 10 Otherincome(loss) 15 Alternative
minimum
tax(AMT)items
A 349.
~-- ----------------------------
F Shareholder'spercentageof stock
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SHAREHOLDER
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EXHIBITL

Tex. Fam. Code§ 7.001
(Vernon 2006)
Downloadedfrom vlex by Marisol Lopez vllex
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Tex. Fam. Code§ 7.001 General Rule of Property Division

Library: Texas Statutes
Edition: 2025
Currency: Current through bills posted as of 6/25/2025 from the 2025 Legislative Session
Citation: Tex. Fam. Code§ 7.001
Year: 2025

Id. vLex Fastcase:VLEX-1078275571

Link: https://fastcase.vlex.com/vid/tex-fam-code--1078275571

August 21, 2025 02:28 1/2
Downloaded from vLex by Marisol Lopez vllex
In a decree of divorce or annulment, the court shall order a division of the estate of the parties in a
manner that the court deems just and right, having due regard for the rights of each party and any
children of the marriage.

History:Added by Act~ 1997, 75th Leg.. ch. 7, Sec. 1, eff. 4/17/1997.

Cite as: Tex. Fam. Code§ 7.001

--~--------•

August 21, 2025 02:28 2/2
EXHIBITM

Tex. Fam. Code § 8.051.
(Vernon 2006)
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Tex. Fam. Code§ 8.051 Eligibility For Maintenance

Library: Texas Statutes
Edition: 2025
Currency: Current through bills posted as of 6/25/2025 from the 2025 Legislative Session
Citation: Tex. Fam. Code§ 8.051
Year: 2025

Id. vlex Fastcase: VLEX-1078361956

Link: https://fastcase.vlex.com/vid/tex-fam-code--1078361956

August 21, 2025 02:29 1/2
Downloadedfromvlex by Marisol Lopez
vllex
In a suit for dissolution of a marriage or in a proceeding for maintenance in a court with personal
jurisdiction over both former spouses following the dissolution of their marriage by a court that lacked
personal jurisdiction over an absent spouse, the court may order maintenance for either spouse only if
the spouse seeking maintenance will lack sufficient property, including the spouse's separate property,
on dissolution of the marriage to provide for the spouse's minimum reasonable needs and:

(1) the spouse from whom maintenance is requested was convicted of or received deferred
adjudiGation for a criminal offense that also constitutes an act of family violence, as defined by Section
71.004, committed during the marriage against the other spouse or the other spouse's child and the
offense occurred:

(A) within two years before the date on which a suit for dissolution of the marriage is filed; or

(B) wbile the suit is pending; or

(2) the spouse seeking maintenance:

(A) is unable to earn sufficient income to provide for the spouse's minimum reasonable needs
because of an incapacitating physical or mental disability;

(B) has been manied to the other spouse for 10 years or longer and lacks the ability to earn
sufficient income to provide for the spouse's minimum reasonable needs; or

(C) is the custodian of a child of the maniage of any age who requires substantial care and
personal supervision because of a physical or mental disability that prevents the spouse from
earning sufficient income to provide for the spouse's minimum reasonable needs.

History:Amended by Acts 2013, 83rd Leg. - Regular Session. ch. 242, Sec. 2, eff. 9/1/2013.
Amended by Acts 2013, 83rd Leg. - Regular Session, ch. 242, Sec. 1, eff. 9/1/2013.
Amended By Acts 2011, 82nd Leg., R.S., Ch. 486, Sec. 1, eff. 9/1/2011.
Amended By Acts 2005. 79th Leg .. Ch. 914, Sec. 1, eff. 9/1/2005.
Amended by Acts 1999. 76th Leg .. ch. 62, Sec. 6.05, eff. 9/1/1999; Acts 1999, 76th Leg., ch. 304,
Sec. 1, eff. Sept. I, 1999. Renumbered from Sec. 8.002 and amended by Acts 20()1, 77th Leg., ch.
807, Sec. I, eff. 9/1/200 I .
Added by Acts 1997, 75th Leg., ch. 7, Sec. I, eff. 4/17/1997.

Cite as: Tex. Fam. Code § 8.051

August 21, 2025 02:29 2/2
EXHIBITN

Tex. Fam. Code§ 8.052
(Vernon 2006)
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Tex. Fam. Code § 8.052 Factors In Determining
Maintenance

Library: Texas Statutes
Edition: 2025
Currency: Current through bills posted as of 6/25/2025 from the 2025 Legislative Session
Citation: Tex. Fam. Code§ 8.052
Year: 2025

Id. vLex Fastcase:VLEX-1078275582

Link: https://fastcase.vlex.com/vid/tex-fam-code--1078275582

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A court that detennines that a spouse is eligible to receive maintenance under this chapter shall
determine the nature, amount, duration, and manner of periodic payments by considering all relevant
factors, including:

(1) each spouse's ability to provide for that spouse's minimum reasonable needs independently,
considering that spouse's financial resources on dissolution of the marriage;

(2) the education and employment skills of the spouses, the time necessary to acquire sufficient
education or training to enable the spouse seeking maintenance to earn sufficient income, and the
availability and feasibility of that education or training;

(3) the duration of the marriage;

(4) the age, employment history, earning ability, and physical and emotional condition of the spouse
seeking maintenance;

(5) the effect on each spouse's ability to provide for that spouse's minimum reasonable needs while
providing periodic child support payments or maintenance, if applicable;

(6) acts by either spouse resulting in excessive or abnormal expenditures or destruction, concealment,
or fraudulent disposition of community property, joint tenancy, or other property held in common;

(7) the contribution by one spouse to the education, training, or increased earning power of the other
spouse;

(8) the property brought to the marriage by either spouse;

(9) the contribution of a spouse as homemaker;

( 10) marital misconduct, including adultery and cruel treatment, by either spouse during the marriage;
and

(11) any history or pattern of family violence, as defined by Section 71.004.

History:Amended By Acts 20 I I, 82nd Leg .. R.S .. Ch. 486, Sec. 1, eff. 9/1/2011.
Added by Acts 1997. 75th Leg .. ch. 7, Sec. I, eff. 4/17/1997. Renumbered from Sec. 8.003 by Acts
2001. 77th Leg .. ch. 807, Sec. 1, eff. 9/1/2001.

Cite as: Tex. Fam. Code§ 8.052

August 21, 2025 02:30 2/2
EXHIBITO

Tex. Fam. Code§ 8.053
(Vernon 2006)
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Tex. Fam. Code § 8.053 Presumption

Library: Texas Statutes
Edition: 2025
Currency: Current through bills posted as of 6/25/2025 from the 2025 Legislative Session
Citation: Tex. Fam. Code§ 8.053
Vear: 2025

Id. vlex Fastcase: VLEX-1078275586

Link: https://fastcase.vlex.comivid/tex-fam-code--1078275586

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(a) It is a rebuttable presumption that maintenance under Section 8.051 (2)(B) is not warranted unless
the spouse seeking maintenance has exercised diligence in:

(1) earning sufficient income to provide for the spouse's minimum reasonable needs; or

(2) developing the necessary skills to provide for the spouse's minimum reasonable needs
during a period of separation and during the time the suit for dissolution of the marriage is
pending.

(b) Repealed by Act~ 201 J. 82nd Leg .. R.S .. Ch. 486, Sec. 9(1), eff. September I, 2011.

History: Amended By Acts 20 IL 82nd Leg .. R.S .. Ch. 486, Sec. 2, eff. 9/1/2011.
Amended By Acts 2011, 82nd Leg., R.S., Ch. 486, Sec. 9(1), eff. 9/1/2011.
Amended By Acts 2005. 79th Leg .. Ch. 914, Sec. 2, eff. 9/1/2005.
Added by Acts 1997. 75th Leg., ch. 7, Sec. I, eff. 4/17/1997. Renumbered from Sec. 8.004 by Acts
200 I, 77th Leg., ch. 807, Sec. 1, eff. 9/1/2001.

Cite as: Tex. Fam. Code § 8.053

August 21, 2025 02:30 2/2
EXHIBITP

Tex. Fam. Code § 8.054
(Vernon 2006)
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Tex. Fam. Code § 8.054 Duration of Maintenance Order

Library: Texas Statutes
Edition: 2025
Currency: Current through bills posted as of 6/25/2025 from the 2025 Legislative Session
Citation: Tex. Fam. Code§ 8.054
Year: 2025

Id. vLex Fastcase:VLEX-1078275585

Link: https://fastcase.vlex.comivid/tex-fam-code--1078275585

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(a) Except as provided by Subsection (b), a court:

(1) may not order maintenance that remains in effect for more than:
(A) five years after the date of the order, if:
(i) the spouses were married to each other for less than 10 years and the eligibility
of the spouse for w horn maintenance is ordered is established under Section
8.051(1); or
(ii) the spouses were married to each other for at least 10 years but not more than
20 years;
(B) seven years after the date of the order, if the spouses were married to each other for at
least 20 years but not more than 30 years; or
(C) 10 years after the date of the order, if the spouses were married to each other for 30
years or more; and

(2) shall limit the duration of a maintenance order to the shortest reasonable period that allows
the spouse seeking maintenance to earn sufficient income to provide for the spouse's minimum
reasonable needs, unless the ability of the spouse to provide for the spouse's minimum
reasonable needs is substantially or totally diminished because of:
(A) physical or mental disability of the spouse seeking maintenance;
(B) duties as the custodian of an infant or young child of the marriage; or
(C) another compelling impediment to earning sufficient income to provide for the
spouse's minimum reasonable needs.

(b) The court may order maintenance for a spouse to whom Section 8.051(2)(A) or (C) applies for as
long as the spouse continues to satisfy the eligibility criteria prescribed by the applicable provision.

(c) On the request of either party or on the court's own motion, the court may order the periodic
review of its order for maintenance under Subsection (b).

(d) The continuation of maintenance ordered under Subsection (b) is subject to the procedural
requirements for a motion to modify as provided by Section 8.057.

History: Amended by Acts 2023, Texas Act<,of the 88th Leg.- ReguJar Session, ch. 443, Sec. 1, eff.
6/9/2023, app. to a motion to continue spousal maintenance under Subchapter B,
Chapter 8, Family Code, that is made on or after the effective date of this Act, regardless of whether
the original spousal maintenance order was rendered before, on, or after that date.
Amended By Act, 20 I 1, 82nd Leg., R.S., Ch. 486, Sec. 3, eff. 9/1/2011.
Amended By Acts 2005, 79th Leg., Ch. 914, Sec. 3, eff. 9/1/2005.
Added by Act"i 1997, 75th Leg., ch. 7, Sec. 1, eff. 4/17/1997. Renumbered from Sec. 8.005 and
amended by Acts 200 I, 77th Leg .. ch. 807, Sec. 1, eff. 9/1/2001.

Cite as: Tex. Fam. Code § 8.054

August 21, 2025 02:31 2/2
EXHIBITQ

Tex. R. CIV. P. 297
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Rule 297. Time to Send Findings of Fact and Conclusions
of Law

Library: Texas Rules of Civil Procedure
Edition: 2025
Currency: As amended through July 31, 2025
Year: 2025
Citation: Tex. R. Civ. P. 297

Id. vlex Fastcase: VLEX-1072477632

Link: https://fastcase.vlex.com/vid/rule-297-time-to-10724 77632

~~- ·--· --~ --
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Within twenty days after a timely request is filed, the court must send its findings of fact and
conclusionsof law to the parties as provided in Rule 21(t)(l0).

If the court fails to send timely findings of fact and conclusionsof law, the party making the request
must, within thirty days after filing the originalrequest, file with the clerk and serve on all other parties
in accordancewith Rule 21a a "Notice of Past Due Findings of Fact and Conclusionsof Law"
which must be immediatelycalled to the attentionof the court by the clerk. Such notice must state the
date the originalrequest was filed and the date the findings and conclusionswere due. Upon filing this
notice, the time for the court to send findings of fact and conclusionsof law is extended to forty days
from the date the originalrequest was filed.

Cite as Tex. R. Civ. P. 297

History:Amended August 7, 2023, effective9/1/2023; amended September 8, 2023, effective
9/8/2023; amended May 28, 2024, effective 5/28/2024.

Note:

Notes and Comments

Comment to 1990 change: To revise the practice and times for findings of fact and conclusionof law.
See also Rules 296 and 298.

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EXHIBITR

Tex. R. CIV. P. 298
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Rule 298. Additional Or Amended Findings of Fact and
Conclusions of Law

Library: Texas Rules of Civil Procedure
Edition: 2025
Currency: As amended through July 31 2025 l

Year: 2025
Citation: Tex. R. Civ. P. 298

Id. vlex Fastcase: VLEX-1072477619

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After the court sends original findings of fact and conclusions of law, any party may file with the clerk
of the court a request for specified additional or amended findings or conclusions. The request for
these findings must be made within ten days after the court sends the original findings and
conclusions. Each request made pursuant to this rule must be served on each party to the suit in
accordance with Rule 21a.

Within ten days after such request is filed, the court must send any additional or amended findings and
conclusions to the parties as provided in Rule 2l(t)(l0). No findings or conclusions shall be deemed
or presumed by any failure of the court to make any additional findings or conclusions.

Cite as Tex. R. Civ. P. 298

History:Amended August 7, 2023, effective 9/1/2023; amended September 8, 2023, effective
9/8/2023; amended May 28, 2024, effective 5/28/2024.

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