motion for Appointment

COUNTY OF BERKS

NO. NAME WITHELD 

  IN THE MATTER OF THE MARIAGE OF NAME WITHELD  AND IN THE INTEREST OF NAME WITHELD    IN THE DISTRICT COURT  233RD JUDICIAL DISTRICT  TARRANT COUNTY, TEXAS 

This motion for Appointment of Receiver is brought by NAME WITHELD  Petitioner, who shows in support:

    1. Petitioner, NAME WITHELD , and Respondent, AARON NAME WITHELD , are the owners of real property located at Lot 10, Block B, of Edgewood, an Addition to the City of Fort Worth, Tarrant County, Texas, according to the map of plat thereof recorded in Cabinet A, Slide 10182, Plat Records, Tarrant County, Texas, and commonly known as 12113 Treeline Dr., Crowley, Texas.

    1. On May 21st, 2021, the parties agreed and it was therefore ordered that the marital residence located at 12113 Treeline Dr., Crowley, Texas was to remain in possession of NAME WITHELD  residing in the residence and paying all costs associated with the residence.

    1. The Parties further agreed and it was therefore ordered that NAME WITHELD  a total sum of $60,000.00 on or before June 1st, 2021. In absence of such payment past June 1st, 2021, the parties agreed and it was therefore ordered that NAME WITHELD  to list the property for sale with a licensed real estate agent who utilized a multiple listing service.

    1. The Parties further agreed and it was therefore ordered that in the absence of payment of $60,000.00 by NAME WITHELD , and in the event the property is not sold by July 31st, 2021, NAME WITHELD  shall be entitled to appoint a receiver to take possession of and sell the residence.

    1. As of the date herein below, NAME WITHELD  has not remitted payment of the sum of $60,000.00 to NAME WITHELD  and the property known as _____- has not been sold. Unless a receiver is appointed to immediately take charge and control the property, there is danger that the order of May 21st, 2021, will remain unenforced. There is no adequate remedy at law except for the appointment of a receiver.

    1. Fees, Expenses, Costs, and Interest

It was necessary for BETHANY CLAY SMITH 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 service rendered in connection with conservatorship and support of the children, judgment for fees, expenses, and costs should be granted against NAME WITHELD  and in favour of NAME WITHELD , and be ordered paid directly to NAME WITHELD  Requests post judgment interest as allowed by law.

NAME WITHELD  prays that the Court grant this motion for Appointment of Receiver.

DATED _______________

BY:____________________________

NAME WITHELD 

[insert address]

[insert contact]

Pro Se

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