Citizen Alerts

Bond Sales

OFFICIAL NOTICE OF SALE

WILLIAMSON-LIBERTY HILL MUNICIPAL UTILITY DISTRICT

(A political subdivision of the State of Texas located within Williamson County)

$725,000

UNLIMITED TAX ROAD BONDS, SERIES 2025

The Board of Directors of Williamson-Liberty Hill Municipal Utility District (the “District”) will publicly receive sealed bids on their $725,000 Unlimited Tax Road Bonds, Series 2025 (the “Bonds”) on Tuesday, August 19, 2025 by 9:00 A.M., CDT, at the offices of the District’s Financial Advisor, Specialized Public Finance Inc., 248 Addie Roy Road, Suite B-103, Austin, Texas 78746. At a meeting on Tuesday, August 19, 2025 at 12:00 P.M., CDT, at the offices of Gray Engineering, Inc., at 8834 North Capital of Texas Highway, Suite 140, Austin, Texas 78759, the Board will immediately take action to reject any and all bids or accept the bid resulting in the lowest net interest cost to the District.

A bid for Bonds may be delivered to the District electronically, by telephone or delivered directly to the District in a sealed envelope addressed to the President and Board of Directors of the District at the Specialized Public Finance Inc. address. All bidders must submit a signed “Official Bid Form” and a bank cashier’s check in the amount of $14,500 made payable to the District as a Good Faith Deposit. Additional terms and conditions related to the submission of a bid for the Bonds are included in the “Official Notice of Sale.”

The Bonds will mature serially on September 1, 2043 through September 1, 2053. The “Official Notice of Sale,” the “Preliminary Official Statement,” and the “Official Bid Form” may be obtained from the District’s Financial Advisor, Specialized Public Finance Inc., 248 Addie Roy Road, Suite B-103, Austin, Texas 78746, 512/275-7300. This notice does not constitute an offer to sell the Bonds but is merely notice of sale of the Bonds as required by Texas state law. The offer to sell the Bonds will be made by means of the “Official Notice of Sale,” the “Preliminary Official Statement,” and the “Official Bid Form.”

Mr. Matt Giardina

President, Board of Directors

Williamson-Liberty Hill Municipal Utility District

3526

Estate Notices

CITATION BY PUBLICATION

THE STATE OF TEXAS, COUNTY OF WILLIAMSON

NO. 25-0669-C368

Style of Case: Lakeview Loan Servicing, LLC vs Unknown Heirs of Michael Don Havens, Deceased

Ashley Marie Krause, Donald D. Bryant In Rem, Randall Wayne Havens In Rem

TO: UNKNOWN HEIRS OF MICHAEL DON HAVENS, DECEASED

NOTICE TO DEFENDANT- GREETING:

“YOU HAVE BEEN SUED. YOU MAY EMPLOY AN ATTORNEY. IF YOU OR YOUR ATTORNEY DO NOT FILE A WRITTEN ANSWER WITH THE CLERK WHO ISSUED THIS CITATION BY 10:00 A.M. ON THE MONDAY NEXT FOLLOWING THE EXPIRATION OF FORTY-TWO DAYS AFTER THE DATE THIS CITATION WAS ISSUED, A DEFAULT JUDGMENT FOR THE RELIEF DEMANDED IN THE PETITION MAY BE TAKEN AGAINST YOU. IN ADDITION TO FILING A WRITTEN ANSWER WITH THE CLERK, YOU MAY BE REQUIRED TO MAKE INITIAL DISCLOSURES TO THE OTHER PARTIES OF THIS SUIT. THESE DISCLOSURES GENERALLY MUST BE MADE NO LATER THAN 30 DAYS AFTER YOU FILE YOUR ANSWER WITH THE CLERK. FIND OUT MORE AT TEXASLAWHELP.ORG.”

YOU ARE HEREBY COMMANDED to appear by filing a written answer to the Plaintiff’s Petition at or before 10:00 o’clock A.M. on the Monday next after the expiration of 42 days after the date of issuance of this citation, the same being, August 27, 2025 - before the Honorable 368th Judicial District Court of Williamson County, Texas, at the Williamson County Justice Center Courthouse, being located at 405 Martin Luther King Street, in the City of Georgetown, Texas. Said Plaintiff’s Petition was filed in said court on the March 27, 2025 in the above entitled cause.

A brief statement of the nature of this suit is as follows, to-wit: THAT THE COURT GRANT RELIEF REQUESTED IN PETITION., as is more fully shown by Plaintiff’s Petition on file in this suit.

The officer executing this writ shall promptly serve the same according to requirements of law, and the mandates hereof, and make due return as the law directs.

ISSUED AND GIVEN UNDER MY HAND AND SEAL of said Court at office, on this the 16th day of July, 2025. ADDRESS OF LEAD ATTORNEY FOR PETITIONER: Lisa David, District Clerk

M. Nicki Compary

PO Box 5026 Fort Lauderdale, Florida 33310

PO Box 24, Georgetown, TX 78627 Williamson County, Texas

(512) 943-1212

BY: Heather Frazier

Heather Frazier, Deputy

3426

CITATION BY PUBLICATION

THE STATE OF TEXAS COUNTY OF WILLIAMSON

TO ALL PERSONS INTERESTED IN THE ESTATE OF ANITA F. PARKER, Cause No. 25-0913-CP4,

in County Court at Law #4 of Williamson County, 405 Martin Luther King Street, Georgetown, Texas 78626.

JANICE F. JOYCE, Applicant, in the above numbered and entitled estate, filed on the 30th day of July, 2025 an APPLICATION FOR DETERMINATION OF HEIRSHIP AND FOR LETTERS OF INDEPENDENT ADMINISTRATION PURSUANT TO SECTION 401.003 OF THE TEXAS ESTATES CODE, of the said estate and requests that the said Court determine who are the heirs and only heirs of the said ANITA F. PARKER, DECEASED, and their respective shares and interest in such estate.

Said application may be heard at 10:00 o’clock a.m. on or after the first Monday next after the expiration of ten days from the date of publication of this citation, at the Williamson County Justice Center in Georgetown, Williamson County, Texas.

All persons interested in said estate are hereby cited to appear before said Honorable Court on or before above mentioned time and place by filing a written answer contesting such application should they desire to do so.

If this citation is not served within 90 days after the date of its issuance, it shall be returned unserved.

Issued and given under my hand and seal of office at Georgetown, Texas, this the 30th day of July, 2025.

Applicant’s Attorney:

Justin M. Jackson

1464 E. Whitestone Blvd., Ste. 201 Cedar Park, TX 78613

Nancy E. Rister

Williamson County Clerk 405 MLK Street, Box 14 Georgetown, Texas 78626

By: /S/C. Dawson, Deputy

3509

NOTICE TO CREDITORS

Notice is hereby given that original Letters Testamentary for the Estate of TOMMY R. JAQUESS, Deceased, were issued on July 30, 2025, in Cause No. 25-0845-CP4, pending in the County Court-At-Law No: Four, Williamson County, Texas, to: TANNA ROGERS JAQUESS.

All persons having claims against this Estate which is currently being administered are required to present them to the undersigned within the time and in the manner prescribed by law.

Estate of TOMMY R. JAQUESS

c/o: TANNA ROGERS JAQUESS, Independent Executor

3892 Skyview Way Round Rock, Texas 78681

DATED the 30th day of July, 2025.

HERITAGE LAW

1625 Williams Drive, Bldg. 1 Georgetown, Texas 78628

Telephone: (512) 930-0529

Email: wendi@heritagelawtx.com

WENDI LESTER EFFLANDT

State Bar No. 24004401

KEELY C. FREUND

State Bar No. 24132411

Attorneys for TANNA ROGERS JAQUESS

3510

NOTICE TO ALL PERSONS HAVING CLAIMS AGAINST THE ESTATE

Notice is hereby given that in Cause No. 25-0794-CP4, styled Estate of Roger Abexar Chapaweston, Deceased, pending in the County Court at Law No. 4 of Williamson County, Texas, original Letters of Administration with Will Annexed were issued on July 22, 2025, to Theresa Canales.

Claims may be presented and addressed to the personal representative of the estate in care of the attorney at the address below.

All persons having claims against this estate are required to present them within the time and in the manner prescribed by law.

Signed on July 30, 2025.

McGINNIS LOCHRIDGE LLP

1111 W. 6th Street, Bldg. B, Suite 400 Austin, TX 78703

512-495-6170 Telephone 512-505-6370 Fax

dpaul@mcginnislaw.com

By: /s/Douglas J. Paul

Douglas J. Paul

State Bar No. 24051170

Attorneys for Independent Administrator with Will Annexed

3512

NOTICE TO CREDITORS

Notice is hereby given that original Letters Testamentary for the Estate of Gwen Burkhardt aka Gwendolyn Jean Burkhardt, Deceased, were issued on July 1, 2025, in Cause No. 25-0658-CP4, pending in the County Court at Law No: 4, Williamson County, Texas, to: Dena Marie Clark.

All persons having claims against this Estate which is currently being administered are required to present them to the undersigned within the time and in the manner prescribed by law.

c/o: Law Office of Jamie Etzkorn, PLLC

925 Main Street, Ste. B Liberty Hill, Texas 78642

DATED the 30th day of July, 2025.

/s/ Jamie Etzkorn

Jamie Etzkorn

Attorney for Dena Marie Clark

State Bar No.: 24047660

925 Main Street, Ste. B Liberty Hill, TX 78642

Telephone: (512) 800-6353 Facsimile: (512) 233-5207

Email: jamie@etzkornlaw.com

3515

NOTICE TO ALL PERSONS HAVING CLAIMS AGAINST

THE ESTATE OF JOHN NATHAN STARK, SR.

DECEASED

Notice is hereby given that Letters Testamentary for the Estate of John Nathan Stark, Sr., Deceased, were issued on July 22, 2025 in Cause Number 25-0783-CP4, pending in the County Court at Law No. 4 of Williamson County, Texas to Sheila Stark. All persons having claims against the Estate of John Nathan Stark, Sr., should present those claims within the time and in the manner prescribed by law to: Sheila Stark, c/o Paula J. Salinas, P.C. at PO Box 2114, Austin, Texas 78768.

3518

NOTICE TO CREDITORS

Notice is hereby given that original Letters Testamentary for the Estate of William D. Wenthe, Sr. AKA William Dean Wenthe, Deceased, were issued on July 24, 2025 in Cause No. 25-0756-CP4, pending in the County Court at Law No. 4, Williamson County, Texas, to: William D. Wenthe II and Bethany H. Thoresen.

All persons having claims against this Estate which is currently being administered are required to present them to the undersigned within the time and in the manner prescribed by law.

c/o: Alexander Cockerill PC

929 East Contour Drive, San Antonio, Texas 78212

3522

NOTICE TO CREDITORS

NOTICE TO CREDITORS

Estate of Helen R. Wenthe AKA Helen Ruby Wenthe AKA Helen Medack Wenthe, Deceased, were issued on July 24, 2025 in Cause No. 25-0758-CP4Notice is hereby given that original Letters Testamentary for the , pending in the County Court at Law No. 4, Williamson County, Texas, to: William D. Wenthe II and Bethany H. Thoresen.

All persons having claims against this Estate which is currently being administered are required to present them to the undersigned within the time and in the manner prescribed by law.

c/o: Alexander Cockerill PC

929 East Contour Drive, San Antonio, Texas 78212

3523

You've been sued

CITATION BY PUBLICATION

Cause # 24-0240-F395

THE STATE OF TEXAS COUNTY OF WILLIAMSON

TO: Ludwin Mendez Chilel

AND TO ALL WHOM IT MAY CONCERN:

Respondent(s): GREETING

NOTICE TO RESPONDENT: “YOU HAVE BEEN SUED. You may employ an attorney. If you or your attorney do not file a written answer with the clerk who issued this citation by 10:00 am on the Monday next following the expiration of 20 days after the date you were served this citation and petition, a default judgment may be taken against you. In addition to filing a written answer with the clerk, you may be required to make initial disclosures to the other parties of this suit. These disclosures generally must be made no later than 30 days after you file your answer with the clerk. Find out more at TexasLawHelp.org”

** If posted at the courthouse door the written answer shall be filed by 10:00 AM on the Monday next following the expiration of 20 days following the 7th day of posting (STRIKE IF PUBLISHED).

The petition of YESENIA YOLANDA LOPEZ CAX, was filed in the 395th Judicial District Court of Williamson County, Texas on the 25th day of January, 2024, numbered 24-0240-F395 and entitled In The Interest Of X.A.A.M.L., A Child.

The suit requests relief as is more fully shown by the Petition on file in this suit.

The court has authority in this suit to render an order in the child’s/children’s interest that will be binding on you, including the termination of the Parent-child Relationship, the determination of paternity and the appointment of a conservator with authority to consent to the child’s/children’s adoption.

ISSUED AND GIVEN UNDER MY HAND AND SEAL of said Court at Williamson County, Texas on this the 30th day of July, 2025.

Attorney for Party requesting citation: Lisa David, District Clerk

Alejandra Martinez

8023 Vantage Drive, Suite 800 San Antonio, Texas 78230

PO Box 24, Georgetown, TX 78627 Williamson County, Texas

(512) 943-1212

BY: Heather Frazier Heather Frazier, Deputy

3511

CITATION BY PUBLICATION

THE STATE OF TEXAS COUNTY OF WILLIAMSON

TO ALL PERSONS INTERESTED IN THE ESTATE OF FU-CHUNG CHANG, DECEASED, Cause No. 25-0918-CP4, in County Court at Law #4 of Williamson County, 405 Martin Luther King Street, Georgetown, Texas 78626.

SHUN-HUNG HSUEN, Applicant in the above numbered and entitled estate, filed on the 31st day of July, 2025 an APPLICATION FOR DETERMINATION OF HEIRSHIP, FOR APPOINTMENT OF INDEPENDENT ADMINISTRATOR, AND FOR ISSUANCE OF LETTERS OF INDEPENDENT ADMINISTRATION of the said estate and requests that the said Court determine who are the heirs and only heirs of the said FU-CHUNG CHANG, DECEASED, and their respective shares and interest in such estate.

If this citation is not served within 90 days after the date of its issuance, it shall be returned unserved.

Issued and given under my hand and seal of office at Georgetown, Texas, this the 31st day of July, 2025.Applicant’s Attorney:

Don E. Walden

8310 N. Capital of Texas Highway Building One, Suite 305 Austin TX 78731

Nancy E. Rister

Williamson County Clerk

405 MLK Street, Box 14 Georgetown, Texas 78626

By: /S/Kathy Klingelberger, Deputy

3517

TO ALL PERSONS INTERESTED IN THE ESTATE OF CALEB JOSEPH COVEY, DECEASED, Cause No. 25-0917-CP4, in County Court at Law #4 of Williamson County, 405 Martin Luther King Street, Georgetown, Texas 78626.

ELIZABETH DYESS COVEY, Applicant, in the above numbered and entitled estate, filed on the 31st day of July, 2025 an APPLICATION FOR DETERMINATION OF HEIRSHIP AND LETTERS OF INDEPENDENT ADMINISTRATION of the said estate and requests that the said Court determine who are the heirs and only heirs of the said CALEB JOSEPH COVEY, DECEASED, and their respective shares and interest in such estate.

If this citation is not served within 90 days after the date of its issuance, it shall be returned unserved.

Issued and given under my hand and seal of office at Georgetown, Texas, this the 31st day of July, 2025.

Applicant’s Attorney:

Terry Davis

105 West Broade Street Leander, TX 78641

Nancy E. Rister

Williamson County Clerk 405 MLK Street, Box 14 Georgetown, Texas 78626

By: /S/S. Klint, Deputy

Bids & Proposals

Construction

Advertisement and Invitation for Bids (TxCDBG Contract No. CDV23-0102)

The City of Florence will receive bids for 2023/2024 TxCDBG Street Improvements until 10:00 A.M. (local time) on Friday, August 29, 2025 at City of Florence City Hall, 851 F.M. 970, Florence, Texas 76527. The bids will be publicly opened and read aloud at that time.

Bids are invited for several items and quantities of work as follows:

Approximately 1,000 LF of pavement improvements on Howell Street and South Love Avenue, including but not limited to road construction, concrete ribbon curb, concrete driveway, bar-ditch regrading, culverts and all related appurtenances.

Bid/Contract Documents, including Drawings and Technical Specifications are on file at Hejl, Lee & Associates, Inc. (Engineer), 206 Taylor Street, Hutto, TX 78634. Copies of the Bid Documents may be obtained by paying $150 with the Engineer for each set of documents obtained. The payment will not be refunded. Electronic copy of the project documents is available free of charge. Bidder will be required to inform themselves of all Addenda duly issued.

A bid bond in the amount of 5 percent of the bid issued by an acceptable surety shall be submitted with each bid. A certified check or bank draft payable to the City of Florence or negotiable U.S. Government Bonds (as par value) may be submitted in lieu of the Bid Bond.

Attention is called to the fact that not less than, the federally determined prevailing (Davis-Bacon and Related Acts) wage rate, as issued by the Texas Department of Agriculture Office of Rural Affairs and contained in the contract documents, must be paid on this project. In addition, the successful bidder must ensure that employees and applicants for employment are not discriminated against because of race, color, religion, sex, sexual identity, gender identity, or national origin.

The City of Florence reserves the right to reject any or all bids or to waive any informalities in the bidding.

Bids may be held by City of Florence for a period not to exceed 60 days from the date of the bid opening for the purpose of reviewing the bids and investigating the bidder’s qualifications prior to the contract award.

CITY OF FLORENCE

BEN DANIEL, MAYOR

All contractors/subcontractors that are debarred, suspended or otherwise excluded from or ineligible for participation on federal assistance programs may not undertake any activity in part or in full under this project.

3471

ADVERTISEMENT FOR BID

Sealed Bids for the construction of the BERRY CREEK HIGHLAND– PHASE 8A will be received at the Austin offices of Kimley-Horn and Associates, Inc., 10814 Jollyville Road, Campus IV, Suite 200, Austin, Texas 78759 (hereafter “Engineer”) until 2:00 PM on Thursday, August 28th, 2025, then publicly opened and read them aloud. The work generally consists of the construction of water, drainage, and street improvements and associated and incidental appurtenances for the continuation of BCH Way in the Berry Creek Highlands subdivision in Georgetown, in Williamson County, Texas.

Digital copies of the bid documents for this project may be obtained by email from the Engineer. Contact AC Steadman (ac.steadman@kimley-horn.com, 512-418-4508) regarding availability of the bid documents. Bid documents may be viewed at no cost at the office of the Engineer during normal working hours.

A Mandatory Pre-Bid Conference for this project will be held at 2:00 PM on Thursday, August 7th, 2025, on Microsoft Teams:

Join on your computer, mobile app, or room device:

https://teams.microsoft.com/l/meetup-join/19%3ameeting_MjE0MTM4YTUtODkyYi00OTViLWIzYTktNjFmYWEwYWU1ZGEw%40thread.v2/0?context=%7b%22Tid%22%3a%227e220d30-0b59-47e5-8a81-a4a9d9afbdc4%22%2c%22Oid%22%3a%22dc7ba03d-1667-4219-a2a6-33536beb61a3%22%7d

Join with a video conferencing device:

Tenant key: 340760667@t.plcm.vc Video ID: 111 040 418 3

Or call in (audio only)

+1 469-250-9294,

Phone conference ID: 623 291 429#

Representatives of the Owner and Engineer will be present to discuss the project. The engineer will distribute to prospecting Bidders a record of such Addenda as Engineer considers necessary in response to discussions or inquiries arising at the conference.

Bids must be accompanied by a bid bond with power of attorney attached or a cashier’s check of five percent (5%) of the total amount bid (sum of all bid items) made payable to Berry Creek (Georgetown) ASLI IX, LLC.

A Bid which, in the opinion of the Owner’s staff, deviates significantly from the contract Documents, and which has not been clarified through a written Addenda prior to Bid submittal deadline, shall be considered an exception to the Contract Documents and grounds for the Bid to be rejected. Owner reserves the right to reject any or all Bids and to waive any informalities and irregularities in Bids received.

Bidders should read and understand all terms and conditions contained in these Contract Documents. Contract Time is of the essence and all Work shall be substantially completed within one hundred eighty (180) calendar days after the Notice to Proceed (A maximum of thirty-five (35) calendar days are included for contingency within these 180 days for construction-related delays (rain days, etc.); No additional days shall be allowed). All Work shall be fully completed and ready for final payment within two hundred ten (210) calendar days after the Notice to Proceed.

CRITICAL DATES:

First Publication – July 30th, 2025

Second Publication – August 6th, 2025

Pre-Bid Meeting – August 7th, 2025

Bid Opening – August 28th, 2025

3482

BCMUD District Landscape Maintenance Services

Brushy Creek Municipal Utility District is requesting bids for the construction of the BCMUD District Landscape Maintenance Services Project.

Sealed Bids will be received at the office of Brushy Creek Municipal Utility District, 16318 Great Oaks Drive, Round Rock, TX 78681, until 1:00 PM local time on Wednesday, August 27, 2025. At that time, the Bids received will be publicly opened and read.

The project includes landscape maintenance services for a 36- month period beginning approximately October 1, 2025, and ending September 30, 2028, with up to three 1-year extensions.

A non-mandatory pre-bid conference for the Project will be held on Thursday, August 7, 2025, at 10:00 AM at the office of Brushy Creek MUD, 16318 Great Oaks Drive, Round Rock, Texas 78681. Attendance at the pre-bid conference is encouraged but not required.

Project information and Bid documents can be found on the Civcast website, www.civcastusa.com.

The Brushy Creek Municipal Utility District, Williamson County, Texas, reserves the right to reject any or all bids, waive any informalities, or make an award to other than the low bidder. It further reserves the right to limit the amount of the award and eliminate a portion of the work or add additional work as required to keep the total contract amount with the funds budgeted; to award any part or combination of parts of the project it deems necessary; and any other rights established under the laws of the State of Texas.

3525

CITY OF GEORGETOWN

The City of Georgetown is accepting sealed proposals for the following:

Request for Proposal No. 202545 Medical Transfer Services

Due: August 18th, at 2:00 PM CT

Electronic proposals must be submitted through the City’s web site at:

https://georgetown.ionwave.net/Login.aspx.

To obtain information on the solicitation and to register for the bid list, go to https://gtowntx.ionwave.net/CurrentSourcingEvents.aspx

3527

CITY OF GEORGETOWN

The City of Georgetown is accepting sealed proposals for the following:

Request for Proposal No. 202547 HVAC Tune-Up Services

Due: September 5th,2025, at 2:00 PM CT

Electronic proposals must be submitted through the City’s web site at:

https://georgetown.ionwave.net/Login.aspx.

To obtain information on the solicitation and to register for the bid list, go to

https://gtowntx.ionwave.net/CurrentSourcingEvents.aspx

3529

CITY OF LIBERTY HILL, TEXAS

On-Call Right-Of-Way Services

RFQ S2025-013

Notice is hereby given that sealed bids will be received by the City of Liberty Hill, Texas for: On-Call Right-Of-Way Services

The City of Liberty Hill (COLH), herein after “City”, is requesting a Statement of Qualifications (SOQ) from qualified land acquisition firms to provide On-Call Right-of-Way Services for various projects. This Request for Qualifications (RFQ) seeks to identify firms capable of delivering general land acquisition services, including but not limited to, title work, negotiations, and full acquisitions.

Response Due Date: Signed and sealed responses are due no later than September 17, 2025 2:00 PM CST, on the date above at

https://libertyhilltx.bonfirehub.com/portal/?tab=openOpportunities BONFIRE INSTRUCTIONS TO RESPONDENTS

Solicitation Number (Bonfire Ref #): RFQ S2025-0013

Solicitation Name (Bonfire Project): On-Call Right-Of-Way Services

Solicitation information can be found on the Liberty Hill Portal located at https://www.libertyhilltx.gov/bids.aspx

3532

School Notices

Public Media Release: Application Free and Reduced-Price School Meals

Goodwater Montessori School announced its policy today for providing free and reduced-price meals for children served under the attached current income eligibility guidelines. Each school/site or the central office has a copy of the policy, which may be reviewed by anyone on request.

Starting on 8/12/2025, Goodwater Montessori School will begin distributing letters to the households of the children in the district about eligibility benefits and any actions households need to take to apply for these benefits. Applications also are available at 710 Stadium Drive Georgetown, TX 78626-4796.

Criteria for Free and Reduced-Price Meal Benefits

The following criteria will be used to determine a child’s eligibility for free or reduced-price meal benefits: Income

1. Household income that is at or below the income eligibility levels

Categorical (Automatic) Eligibility

2. Household receiving Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF); or Food Distribution Program on Indian Reservations (FDPIR) Program Participant

3. Child’s status as a foster child, homeless, runaway, migrant, or displaced by a declared disaster 4. Child’s enrollment in Head Start or Even Start

Income Eligibility

For those households that qualify for free or reduced-price meals based on income, an adult in the household must complete an application for free and reduced-price meals and return it to Sharmayne Smith, Child Nutrition Director, Sharmayne.smith@goodwatermontessori.org. Those individuals filling out the application will need to provide the following information:

1. Names of all household members

2. Amount, frequency, and source of current income for each household member

3. Last 4 digits of the Social Security number of the adult household member who signs the application or, if the adult does not have a social security number, check the box for “No Social Security number” 4. Signature of an adult household member attesting that the information provided is correct Categorical or Program Eligibility

Goodwater Montessori School is working with local agencies to identify all children who are categorically and program eligible. Goodwater Montessori School will notify the households of these children that they do not need to complete an application. Any household that does not receive a letter and feels it should have should contact Sharmayne Smith, Child Nutrition Director, Sharmayne.smith@goodwatermontessori.org. Any household that wishes to decline benefits should contact Sharmayne Smith, Child Nutrition Director, Sharmayne.smith@goodwatermontessori.org. Applications may be submitted anytime during the school year. The information provided by households on the

application will be used for the purpose of determining eligibility. Applications may also be verified by the school officials at any time during the school year.

Determining Eligibility

Under the provisions of the free and reduced-price meal policy Sharmayne Smith, Child Nutrition Director, Sharmayne.smith@goodwatermontessori.org will review applications and determine eligibility. Households or guardians dissatisfied with the Reviewing Official’s eligibility determination may wish to discuss the decision with the Reviewing Official on an informal basis. Households wishing to make a formal appeal for a hearing on the decision may make a request either orally or in writing to Bruce Tabor, Superintendent, bruce.tabor@goodwatermontessori.org.

Unexpected Circumstances

If a household member becomes unemployed or if the household size increases, the household should contact the school. Such changes may make the children of the household eligible for benefits if the household’s income falls at or below the attached current income eligibility guidelines.

In accordance with federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, this institution is prohibited from discriminating on the basis of race, color, national origin, sex, disability, age, or reprisal or retaliation for prior civil rights activity. Program information may be made available in languages other than English. Persons with disabilities who require alternative means of communication to obtain program information (e.g., Braille, large print, audiotape, American Sign Language), should contact the responsible state or local agency that administers the program or USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339. To file a program discrimination complaint, a Complainant should complete a Form AD-3027, USDA Program Discrimination Complaint Form which can be obtained online at: https://www.usda.gov/sites/default/files/documents/ad-3027.pdf, from any USDA office, by calling (866) 632-9992, or by writing a letter addressed to USDA. The letter must contain the complainant’s name, address, telephone number, and a written description of the alleged discriminatory action in sufficient detail to inform the Assistant Secretary for Civil Rights (ASCR) about the nature and date of an alleged civil rights violation. The completed AD-3027 form or letter must be submitted to USDA by: (1) mail: U.S. Department of Agriculture Office of the Assistant Secretary for Civil Rights 1400 Independence Avenue, SW Washington, D.C. 20250-9410; or (2) fax: (833) 256-1665 or (202) 690-7442; or (3) email: Program.Intake@usda.gov. This institution is an equal opportunity provider.

3514

Booze News

LEGAL NOTICE

Notice is hereby given in accordance with the terms and provisions of the Texas Alcoholic Beverage Code that Speedy Stop Spirits LLC, has filed its Application for the Package Store Permit and Local Distributor's Permit for the operations of Speedy Stop Spirits #101, to be located at 220 State Highway 195, Ste. 100; Georgetown, Williamson County, Texas.

C.L. THOMAS, INC. - MANAGER

CLIFTON L. THOMAS, JR. - CEO/SECY/DIR of C.L. Thomas, Inc.

JOSHUA A. TEINERT - PRESIDENT

CASEY L. SHELLENBARGER - CFO/TREAS.

ASHLIE A. THOMAS - VP

WHITNEY G. THOMAS - VP

3506

An original application has been made with the Texas Alcoholic Beverage Commission for a Wine and Beer Retailer’s On-Premise Permit by Barking Armadillo Drafthouse a Texas Limited Liability Company dba Barking Armadillo Social located at 2080 Westinghouse Rd. Suite 110, Georgetown, Texas, Williamson County, 78626. Members of said company are Jacob Trimm and Sarah Mulvaney.

3508

Petition for

Pre-suit Discovery

IN RE: NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

IN THE DISTRICT COURT 395th JUDICIAL DISTRICT WILLIAMSON COUNTY, TEXAS

NOTICE OF HEARING ON PETITIONERS’ PETITION FOR PRE-SUIT DISCOVERY

Please take notice that a hearing on Petitioners’, Nikolas Putman, Robert Schubert, and Matterhorn Express Pipeline, LLC, Verified Petition for Pre-Suit Discovery (the “Petition”) is set for hearing on: August 27, 2025, at 9:00 a.m., in person, in the 395th Judicial District Court of Williamson County, Texas. The Court’s address is 405 Martin Luther King Street, Georgetown, Texas 78626.

Pursuant to Rule 202.3(a) of the Texas Rules of Civil Procedure, this Notice is being served, together with a copy of Petitioners’ Petition, in accordance with Rule 21a on those persons Petitioners seek to depose and all persons Petitioners expect to have an adverse interest in a potential future suit.

Pursuant to Rule 202.3(a) of the Texas Rules of Civil Procedure, this Notice is also being published, together with a copy of Petitioners’ Petition.

Respectfully submitted,

Ross Molina Oliveros, P.C.

4118 Pond Hill Road, Suite 100 San Antonio, Texas 78231

(210) 249-3200 – Telephone

(210) 249-3201 – Facsimile

/s/ Ramon A. Molina

Ramon A. Molina, Attorney-in-Charge

State Bar No. 24032872

ramolina@rmolawfirm.com

Andrew Stephens

State Bar No. 24082559

astephens@rmolawfirm.com

ATTORNEYS FOR PETITIONERS,

NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

COMES NOW, Petitioners, Nickolas Putman (“Putman”), Robert Schubert (“Schubert”), and Matterhorn Express Pipeline, LLC (“Matterhorn” and collectively with Putman and Schubert as the “Petitioners”), filing this, their Verified Petition for Pre-Suit Discovery (the “Petition”) seeking: (1) to take written and/or oral depositions and (2) the production of relevant documents in anticipation of a future lawsuit and to fully investigate whether other potential claims or persons should be included in said suit, and would respectfully show the Court as follows: VERIFICATION

1. Pursuant to Rule 202.2(a), Petitioners attach to this Petition the verification and Affidavit of Nick Putman (the “Putman Affidavit”), as Petitioners’ Exhibit A. JURISDICTION & VENUE

2. This Court has jurisdiction over this matter under Rule 202 of the Texas Rules of Civil Procedure. A future suit, if filed, would have damages in excess of the Court’s minimal jurisdictional requirements. Venue is proper in Williamson County under Rule 202, since all or a substantial part of the events or omissions giving rise to any future claim or claims occurred in Williamson County and venue for this Petition may lie in the County of an anticipated suit.

PARTIES & SUBJECT MATTER

3. Petitioner, Nickolas Putman, is an individual with his primary residence and domicile located in Morehouse Parish County, Louisiana.

4. Petitioner, Robert Schubert, is an individual with his primary residence and domicile located in Kendall County, Texas.

5. Petitioner, Matterhorn Express Pipeline, LLC, is a Delaware limited liability company, and is authorized to transact business in the State of Texas.

6. Petitioners anticipate the institution of a suit against certain individuals, in which one or more of the Petitioners may be parties. Further, Petitioners seek to investigate potential claims they may have as part of the anticipated suit.

7. The subject matter of the anticipated action includes, but is not limited to, claims against an unknown individual who assaulted Putman and Schubert (the “Unknown Pilot”), while they were acting as agents of Matterhorn. Specifically, on February 20, 2024, Putman and Schubert were working directly on Matterhorn’s behalf and at its instruction to stake a recently acquired easement on property in Williamson County, Texas (the “Property”). The Property is owned by NMCV Taylor Property Investors, LLC, and Mr. Emory Stromberg is believed to have either been the lessee or the tenant at the time of the incident.

8. While Putman and Schubert were working on the Property, the Unknown Pilot intentionally assaulted them by flying low overhead and “crop dusting” the agents with pesticides and/or smoke. See Petitioners’ Exhibit A. After Putman and Schubert were assaulted, they immediately ran to their nearby truck. See Petitioners’ Exhibit A. Before Putman and Schubert got into the truck, the Unknown Pilot proceeded to fly overhead again, this time crop dusting the truck. See Petitioners’ Exhibit A.

9. After the assault, Putman and Schubert agents contacted their superiors and immediately sought medical attention and treatment. Id.

10. After being notified of its agents being assaulted, Matterhorn began investigating the incident and reached out to Mr. Stromberg to obtain the necessary information to identify the Unknown Pilot and the pesticides and/or smoke that Putman and Schubert were sprayed with. Mr. Stromberg admitted he was familiar with the incident and admitted to having personal knowledge of the assault, although he claims the Unknown Pilot “only” used smoke—not pesticides. Unfortunately, despite Matterhorn’s request, Mr. Stromberg refused to provide any information on the identity of the Unknown Pilot.

11. Upon information and belief, the Unknown Pilot and/or Mr. Stromberg acquired the chemicals to be used to crop-dust the Property from Helena Agri-Enterprises, LLC (“Helena”), which has a location in nearby Taylor, Texas.

12. Since the assault, Putman has experienced breathing and coughing problems. See Petitioners’ Exhibit A.

13. The pre-suit discovery requested in this Petition is necessary to prevent a failure or delay of justice. Specifically, Petitioners must be afforded the opportunity to identify the Unknown Pilot to bring suit. Further, the importance of allowing Petitioners to conduct pre-suit discovery on these narrow issues outweighs the burden or expense of the procedure and, at the very least, will allow Petitioners to fully evaluate potential claims and thereby prevent filing unnecessary claims

and naming unnecessary defendants.

14. Petitioners expect the following unknown person to have adverse interests in any future claim or suit:

a. The Unknown Pilot, a.k.a. John Doe. The Unknown Pilot crop dusted Putman and Schubert while they were acting on behalf of and at Matterhorn’s direction as its

agents and were within the scope of their work. Based on conversations with Mr. Stromberg, the Unknown Pilot is believed to be “a professional pilot” that has “flown for many years in [the Williamson County] area.” Despite Matterhorn’s requests, Mr. Stromberg has refused to identify the Unknown Pilot, necessitating, in part, this Petition.

15. Despite diligent inquiry, Petitioners are unable to ascertain the name, address, or telephone number of the Unknown Pilot. Accordingly, Petitioners will provide the statutorily required notice to the Unknown Pilot via publication pursuant to Rule 202. See TEX. R. CIV. P. 202.3(b).

REQUESTED DISCOVERY

16. Petitioners seek to depose, via written and/or oral depositions, and obtain documents from, via discovery requests, the following persons and/or entities:

a. Mr. Emory Stromberg:

1721 County Road 368

Taylor, Texas 76574

(512) 914-2826

Petitioners expect to elicit from Mr. Stromberg, by deposition or the production of documents, the identity of the Unknown Pilot and information concerning the assault of Putman and Schubert, and the chemicals used therein. Petitioners also expect to ascertain whether the Unknown Pilot acted within the scope of his employment and whether any other persons were involved in the Unknown Pilot’s assault of Putman and Schubert.

While Petitioners do not presently anticipate any claims against Mr. Stromberg individually, in an abundance of caution and based on his refusal to willingly provide information to concerning the identity of the Unknown Pilot, Petitioners note that Mr. Stromberg may take the position that his interest is adverse to Petitioners.

b. Helena Agri-Enterprises, LLC:

c/o C. T. Corporation System, as registered agent

1999 Bryan St., Suite 900

Dallas, Texas 75201-3136

Helena is a Delaware limited liability company and is registered to, and is currently, doing business in the State of Texas.

Petitioners expect to elicit from Helena, by deposition or the production of documents, information concerning the chemical composition of, and health and safety warnings associated with chemicals sold to the Unknown Pilot. Petitioners also expect to ascertain the identity of the Unknown Pilot.

17. Petitioners desire to obtain the expected testimony and documents from Mr. Stromberg and Helena to fully investigate claims to be made against the Unknown Pilot and to discover information directly related to the health and safety of Putman and Schubert. Matterhorn intends to initially seek the information it needs from Mr. Stromberg and Helena through depositions on written questions and requests for production. If additional information is needed thereafter, Petitioners reserve the right to take the oral depositions of Mr. Stromberg and/or a representative of Helena1.

REQUEST FOR RELIEF

18. For the reasons above, Petitioners request the Court set this Petition for a hearing, that notice be provided to the Unknown Pilot, Mr. Stromberg, and Helena as prescribed by the Rules, and that, after the hearing, the Court order and permit the pre-suit discovery contemplated and sought as part of this Petition to be sent to Mr. Stromberg and Helena, including depositions on written questions and requests for production, and, if necessary, oral depositions. To the extent necessary, Petitioners hereby attach drafts of their anticipated Notices of Deposition by Written Questions and corresponding Requests for Production hereto collectively as Petitioners’ Exhibits B-1, B-2, B-3, and B-4.

1 To the extent it becomes clear that Petitioners needs to conduct additional pre-suit discovery directed to the Unknown Pilot, they will amend this Petition at that time and will resubmit the Petition for consideration by the Court.

PRAYER

WHEREFORE, PREMISES CONSIDERED, Petitioners respectfully request the Court to set this Petition for hearing and, after the hearing, permit pre-suit discovery to be sent to Mr. Stromberg and Helena, including depositions on written questions, requests for production, and, if necessary, oral depositions.

Petitioners also pray for such other and further relief to which they may be justly entitled, in law or in equity.

Respectfully submitted,

ROSS MOLINA OLIVEROS, P.C.

4118 Pond Hill Road, Suite 100

San Antonio, Texas 78231

(210) 249-3200 – Telephone

(210) 249-3201 – Facsimile

By: /s/ Ramon A. Molina

Ramon A. Molina, Attorney-in-Charge

State Bar No. 24032872

ramolina@rmolawfirm.com

Andrew Stephens

State Bar No. 24082559

astephens@rmolawfirm.com

ATTORNEYS FOR PETITIONERS,

NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

EXHIBITA

EXHIBIT A

AFFIDAVIT OF NICK PUTMAN

STATE OF Louisiana

PARISH of West Carroll

Before me, the undersigned authority, personally appeared Nickolas Putman who, being by me duly sworn, stated as follows:

I. “My name is Nickolas Putman I am over 21 years of age, am of sound mind, and I am fully competent to make this affidavit. The facts set forth in this affidavit are within my personal knowledge and are true and correct.

2. On February 20, 2024, I was working for TableRock Survey near Taylor, Texas with Robert Schubert to stake the Right of Way (ROW) for the Matterhorn Pipeline on property owned by NMCV Taylor Property Investors, LLC (the “Property’”’).

3. The ROW on the Property is located along the Northern and Eastern boundaries. A depiction of the ROW on the Property is attached hereto as Exhibit 1.

4. When we arrived that morning, we parked my truck within the ROW on the Property and started measuring and staking the Northern portion of the ROW.

5. After about 1,000 feet, Robert and I noticed a crop-dusting plane, which began spraying the South end of the Property.

6. As we finished our work on the Northern end and turned South to move along the Eastern portion of the ROW, the crop-dusting plane flew across the Property and flew over our heads really low to the ground. The plane then turned around and flew back over us and sprayed us with something before flying to my truck and spraying it as well.

7. After spraying my truck, the crop-dusting plane immediately flew away.

8. I do not know what the crop-dusting plane sprayed me, Robert, or my truck with, but it burned my eyes and skin and hurt to breathe in.

9. Once the smoke cleared, Robert and I immediately got inside my truck. Then I called my supervisor to let him know what happened, and he told me to let him make a call and he would call me back.

10. While I was waiting for my supervisor to call me back, Mr. Stromberg drove his Jeep onto the Property and stopped in front of my truck and got out and began accusing us of calling the police on the pilot of the crop-dusting plane.

as I told Mr. Stromberg that we did not call the police, only my supervisor and that we were waiting for him to call us back. Mr. Stromberg then drove away.

12. My supervisor then called back and Robert and I were instructed to leave the Property, go change our clothes, and to visit a clinic in Lampasas, Texas.

13. Since the initial visit to the clinic, I have been to the Emergency Room numerous times with problems breathing and coughing, and none of the doctors were able to determine why I was having problems. Two of the visits were to the Morehouse ER in Bastrop, Louisiana.

14. I’ve visited my regular doctor in Start, Louisiana and they ran tests and said I did not have the flu or COVID and that they couldn’t understand why I was having issues breathing.

Further affiant sayeth naught.”

/s/ NICKOLAS PUTMAN

NICKOLAS PUTMAN

SWORN TO AND SUBSCRIBED before me on the 13 day of May2025.

/s/ Patrician H. Copes #041017

Notary Public, State of Louisiana

EXHIBIT B-1

PETITIONERS’ EXHIBIT B-1

IN RE: NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC IN THE DISTRICT COURT ___ JUDICIAL DISTRICT WILLIAMSON COUNTY, TEXAS

PETITIONERS’ PRE-SUIT

REQUESTS FOR PRODUCTION TO EMORY STROMBERG

To: Mr. Emory Stromberg, 1721 County Road 368, Taylor, Texas 76574 Pursuant to Rule 196 of the Texas Rules of Civil Procedure and the Court’s authorization of pre-suit discovery in the above referenced cause, Petitioners, Nickolas Putman (“Putman”), Robert Schubert (“Schubert”), and Matterhorn Express Pipeline, LLC (“Matterhorn” and collectively with Putman and Schubert as the “Petitioners”) serve these Pre-Suit Requests for Production. Please produce all requested documents as they are kept in the ordinary course of business, organized, and labeled to correspond with categories in each request, for inspection and copying, not more than thirty days after service, at the law offices of ROSS MOLINA OLIVEROS, P.C., 4118 Pond Hill Rd., Suite 100, San Antonio, Texas 78231.

Respectfully submitted,

ROSS MOLINA OLIVEROS, P.C.

4118 Pond Hill Road, Suite 100 San Antonio, Texas 78231

(210) 249-3200 – Telephone (210) 249-3201 – Facsimile

By: /s/ Ramon A. Molina

Ramon A. Molina, Attorney-in-Charge

State Bar No. 24032872

ramolina@rmolawfirm.com

Andrew Stephens

State Bar No. 24082559

astephens@rmolawfirm.com

ATTORNEYS FOR PETITIONERS, NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

PETITIONERS’ EXHIBIT B-1

CERTIFICATE OF SERVICE

I hereby certify that on this ___ day of ___________________ 2025, this document was served by the method indicated, pursuant to Rule 21a of the Texas Rules of Civil Procedure:

Emory Stromberg 1721 County Road 368 Taylor, Texas 76574 FIRST CLASS RRR#

(512) 914-2826

/s/ Ramon A. Molina

Ramon A. Molina

PETITIONERS’ EXHIBIT B-1

PRE-SUIT REQUESTS FOR PRODUCTION

A. Instructions

1. Serve a written response to each of the attached Requests for Production within thirty (30) days following service. With respect to each item or category of items requested, state whether: (1) production and/or inspection will be permitted when and as requested; (2) the requested items are being served with the response; or (3) no responsive items have been identified, after a diligent search.

2. With respect to production, produce all responsive documents in your possession, custody or control with the responses or at the offices of the undersigned counsel within thirty (30) days following service of the Requests for Production.

3. These Requests are continuing in nature and require supplementation or amendment as soon as practicable if you or your attorney obtain information which reveals that your answers were incorrect or incomplete when made or that your answers are no longer correct or complete.

4. Your failure to respond to these Requests as required by the Texas Rules of Civil Procedure in the manner and within the time required may result in entry of judgment against you, assessment of attorneys’ fees against you, or other sanctions as determined by the Court.

5. Documents produced pursuant to these Requests should be tendered either in the precise form or manner as they are kept in the usual course of business or organized and labeled to correspond with the categories in the Requests to which they respond.

6. The requested documents include those within your possession, custody or control. If any document requested herein has been destroyed or is no longer in your possession, custody or control, describe in detail the circumstances of and reasons for such loss of possession or destruction, identify the current location of the document and/or who has current possession, custody or control, and produce all documents which relate to either the circumstances or the reasons for such loss of possession or destruction.

7. If any document responsive to a Request, as requested herein, is withheld under claim of privilege, pursuant to TEX. R. CIV. P. 193.3, provide the following information concerning the same: (1) that the document responsive to the Request has been withheld; (2) Request to which the information or document relates; (3) the specific privilege or privileges asserted for each item or group of items withheld; and (4) without revealing the privileged information itself or otherwise waiving the privilege, describe the information or documents withheld sufficiently to allow the assessment of the applicability of the privilege.

8. Unless otherwise stated within a Request, no Request herein seeks documents, tangible things or information discoverable exclusively under Rules 194.2(f) or 195 pertaining to testifying experts. These Requests do, however, apply to (i) any non privileged consulting experts, and (ii) any documents, tangible things and information that you discovered, prepared and/or possess independently of a testifying expert, even if a testifying expert also discovered, prepared and/or possesses them.

B. Definitions

The following words have the following meanings, unless the context requires otherwise:

1. The term “Petitioners” as used herein shall collectively mean Petitioners, Nickolas Putman, Robert Schubert, and Matterhorn Express Pipeline, LLC and, when applicable, their agents, representatives, officers, directors, employees, partners, corporate agents, subsidiaries, or affiliates.

2. “Mr. Stromberg,” “You,” and “Your” collectively mean and refer to the above-named person on whom these requests have been served, and any person acting on their behalf.

3. The term “Property” is defined in Petitioners’ Verified Petition for Pre-Suit Discovery, and any supplements or amendments thereto, and refers to the tract of land where the crop dusting incident took place in Williamson County, Texas.

4. The term “document” is used herein in its broadest sense to include any medium upon or with which information is recorded or preserved which belongs to, or is in or subject to the possession, custody, or control of, any of the parties named hereinabove, by whomever generated or received, including without limitation: writings; printings; drawings; graphs; charts; notes; typewritings; photographs; slides; motion pictures; videotapes or cassettes; phonograph records; tape, video or other mechanical recordings; computer records, information storage devices, disks, or printouts; brochures; pamphlets; maps; surveys; calendars; contracts; interoffice communications; telephone recordings; ledgers; books; statements of account; journals; notices; letters; catalogs; canceled checks; bank statements; invoices; bills; diaries; purchase orders; memoranda of telephone communications; telegrams; telexes or “TWX’s”; telecopies; drafts or preliminary versions of the foregoing; communications to or from any governmental or law enforcement sub division, officer, or agency; and, any other instrument, writing, recording, or data compilation of any nature whatsoever, including any carbon, photographic, microfilm, or other type of copy of such items, if such copy is different from the original by reasons of any markings, additions, commentaries, revisions, deletions, or substitutions. The documents requested include any responsive data or information that exists in electronic or magnetic form and any such data or information should be produced in the electronic or magnetic form in which it exists.

5. The term “person” as used herein shall mean and include an individual, sole proprietorship, association, firm, partnership, joint venture, corporation, board, committee, agency, commission, or any other legal entity of any type for any purpose, whether public or private.

6. The terms “relating,” “related,” “reflecting,” or “evidencing,” when used in referencing a certain subject or thing as used herein, shall mean and include to reflect, to evidence, to mention, to discuss, to describe, to explain, to embody, to constitute, or to include that subject or thing.

7. The term “or” as used herein shall mean and include “and” or “and/or.”

8. The term “all” as used herein shall mean “any” and “all.”

9. The term “including”, as used herein, shall mean “including, but not limited to.”

10. The terms “fact” and “facts” as used herein shall include, without limitation, every relevant matter, occurrence, act, event, transaction, occasion, meeting, document, instance, circumstance, recitation, writing, or other happening.

11. The term “communication” as used herein is used in its broadest sense and shall mean oral conversations, whether telephone or face-to-face, discussions, meetings, conferences, speeches and hearings, written communications, whether letter, facsimile, or electronic transmission, and internal and external communications, and shall include both word and visual communication of any kind whatsoever.

12. The term “Unknown Pilot” is defined in Petitioners’ Verified Petition for Pre-Suit Discovery.

13. The term “Relevant Time Frame” as used herein shall mean from February 1, 2024 to the present.

14. Certain other terms may be defined within the requests for documents herein.

C. Requests for Production

Request for Production No. 1: Produce all documents and communications between you and the Unknown Pilot during the Relevant Time Frame regarding the Property, work to be performed on the Property, and concerning the events of February 20, 2024 as set forth in Petitioners’ Verified Petition for Pre-Suit Discovery.

Response:

Request for Production No. 2: Produce all documents concerning payments made by You to the Unknown Pilot during the Relevant Time Frame.

Response:

Request for Production No. 3: Produce all documents evidencing any pesticides or other products purchased for the purpose of crop-dusting the Property during the Relevant Time Frame. This Request includes, but is not limited to, any available health and safety related information or warnings for said chemicals or products.

Response:

Request for Production No. 4: Produce all documents evidencing the chemicals or products used on the Property to treat crops via crop-dusting during the Relevant Time Frame, regardless of whether said chemicals or products were purchased during the Relevant Time Frame. This Request includes, but is not limited to, any available health and safety related information or warnings for said chemicals or products.

Response:

EXHIBIT B-2

PETITIONERS’ EXHIBIT B-2

CAUSE NO. _______________________ IN RE: NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

IN THE DISTRICT COURT __ JUDICIAL DISTRICT WILLIAMSON COUNTY, TEXAS

PETITIONERS’ PRE-SUIT

DEPOSITION ON WRITTEN QUESTIONS TO EMORY STROMBERG To: Mr. Emory Stromberg, 1721 County Road 368, Taylor, Texas 76574 PLEASE TAKE NOTICE that under Texas Rule of Civil Procedure 200, Petitioners, Nickolas Putman (“Putman”), Robert Schubert (“Schubert”), and Matterhorn Express Pipeline, LLC (“Matterhorn” and collectively with Putman and Schubert as the “Petitioners”), will take the deposition by written questions of Mr. Emory Stromberg (“Deponent”), pursuant to the Court’s authorization of pre-suit discovery in the above referenced cause, at __:00 __.m. on __________ __, 2024, at the offices of ROSS MOLINA OLIVEROS, PC, 4118 Pond Hill Road, Ste. 100, San Antonio, Texas, or on a date and at a location mutually agreed upon by the Deponent and Petitioners. Deponent will be required to answer the questions listed in Exhibit B, attached hereto and made a part hereof before a certified court reporter authorized to take depositions in Texas.

Respectfully submitted,

ROSS MOLINA OLIVEROS, P.C.

4118 Pond Hill Road, Suite 100 San Antonio, Texas 78231

(210) 249-3200 – Telephone (210) 249-3201 – Facsimile

By: /s/ Ramon A. Molina

Ramon A. Molina, Attorney-in-Charge

State Bar No. 24032872

ramolina@rmolawfirm.com

Andrew Stephens

State Bar No. 24082559

astephens@rmolawfirm.com

ATTORNEYS FOR PETITIONERS,

NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

PETITIONERS’ EXHIBIT B-2

CERTIFICATE OF SERVICE

I hereby certify that on this ___ day of ___________________ 2025, this document was served by the method indicated, pursuant to Rule 21a of the Texas Rules of Civil Procedure:

Emory Stromberg

1721 County Road 368 Taylor, Texas 76574

(512) 914-2826

FIRST CLASS MAIL RRR#

/s/ Ramon A. Molina

Ramon A. Molina

PETITIONERS’ EXHIBIT B-2

EXHIBIT “A”

Definitions and Instructions for Written Questions under Exhibit “B” The following words have the following meanings, unless the context requires otherwise:

2. “Mr. Stromberg,” “You,” and “Your” collectively mean and refer to the above-named person on whom these requests have been served, and any person acting on their behalf.

7. The term “or” as used herein shall mean and include “and” or “and/or.”

8. The term “all” as used herein shall mean “any” and “all.”

9. The term “including”, as used herein, shall mean “including, but not limited to.”

12. The term “Unknown Pilot” is defined in Petitioners’ Verified Petition for Pre-Suit Discovery.

13. The term “Relevant Time Frame” as used herein shall mean from February 1, 2024 to the present.

14. Certain other terms may be defined within the requests for documents herein.

EXHIBIT “B”

CAUSE NO. _______________________

IN RE: NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

IN THE DISTRICT COURT ___ JUDICIAL DISTRICT WILLIAMSON COUNTY, TEXAS

Written Questions

1. Please state your full name, occupation, and address.

Response:

_______________________________________________________________________

2. Are you of sound mind, capable of answering these questions, signing the verification, and personally acquainted with the facts therein?

Response:

_______________________________________________________________________

3. Please state the full name, occupation, employer, address, and any other available contact information (i.e. email, phone number) for the Unknown Pilot.

Response:

_______________________________________________________________________

4. Please briefly summarize the substance of any communications you had with the Unknown Pilot during the Relevant Time Frame concerning the events of February 20, 2024 as set forth in Petitioners’ Verified Petition for Pre-Suit Discovery.

Response:

_______________________________________________________________________

5. Please identify the chemicals or products purchased during the Relevant Time Frame for use on the Property to treat crops via crop-dusting. Please include, as part of Your Response, any available health and safety related information or warnings for any identified chemicals or products.

Response:

_______________________________________________________________________

6. Please identify the chemicals or products used on the Property to treat crops via crop dusting during the Relevant Time Frame, regardless of whether said chemicals or products were purchased during the Relevant Time Frame. Please include, as part of Your Response, any available health and safety related information or warnings for any identified chemicals or products.

Response:

_______________________________________________________________________

7. Please identify any person You have communication with concerning the events of February 20, 2024 as set forth in Petitioners’ Verified Petition for Pre-Suit Discovery. Please include, as part of your Response, the contact information for person identified as well as a brief description of the general substance of any communications.

Response:

_______________________________________________________________________

8. Please identify your relationship with the Unknown Pilot.

Response:

_______________________________________________________________________

SIGNED the _____ day of ________________, 2025.

__________________________________

Name of Deponent

VERIFICATION

Before me, the undersigned notary, on this day, appeared ______________, a person whose identity is known to me. After I administered an oath to _____________, he testified:

“My name is _____________. I am capable of making this verification. I verify that the responses contained herein are true and correct to the best of my knowledge.”

SWORN TO AND SUBSCRIBED before me by _____________, on this _______ day of __________________, 2025, to certify which witness my hand and official seal.

________________________________

Notary Public, State of Texas

Printed name:

____________________________

Commission Expires

EXHIBIT B-3

PETITIONERS’ EXHIBIT B-3

CAUSE NO. _______________________

IN RE: NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

IN THE DISTRICT COURT ___ JUDICIAL DISTRICT WILLIAMSON COUNTY, TEXAS

PETITIONER’S PRE-SUIT

REQUESTS FOR PRODUCTION TO HELENA AGRI-ENTERPRISES, LLC

To: Helena Agri-Enterprises, LLC, c/o C. T. Corporation System, as registered agent, 1999 Bryan St., Suite 900, Dallas, Texas 75201-3136

Pursuant to Rule 196 of the Texas Rules of Civil Procedure and the Court’s authorization of pre-suit discovery in the above referenced cause, Petitioners, Nickolas Putman (“Putman”), Robert Schubert (“Schubert”), and Matterhorn Express Pipeline, LLC (“Matterhorn” and collectively with Putman and Schubert as the “Petitioners”), serves these Pre-Suit Requests for Production. Please produce all requested documents as they are kept in the ordinary course of business, organized, and labeled to correspond with categories in each request, for inspection and copying, not more than thirty days after service, at the law offices of ROSS MOLINA OLIVEROS, P.C., 4118 Pond Hill Rd., Suite 100, San Antonio, Texas 78231.

Respectfully submitted,

ROSS MOLINA OLIVEROS, P.C.

4118 Pond Hill Road, Suite 100 San Antonio, Texas 78231

(210) 249-3200 – Telephone (210) 249-3201 – Facsimile

By: /s/ Ramon A. Molina

Ramon A. Molina, Attorney-in-Charge

State Bar No. 24032872

ramolina@rmolawfirm.com

Andrew Stephens

State Bar No. 24082559

astephens@rmolawfirm.com

ATTORNEYS FOR PETITIONERS,

NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

PETITIONERS’ EXHIBIT B-3

CERTIFICATE OF SERVICE

I hereby certify that on this ___ day of __________________ 2025, this document was served by the method indicated, pursuant to Rule 21a of the Texas Rules of Civil Procedure:

Helena Agri-Enterprises, LLC: c/o C. T. Corporation System, as registered agent 1999 Bryan St., Suite 900 Dallas, Texas 75201-3136

FIRST CLASS MAIL RRR#

/s/ Ramon A. Molina

Ramon A. Molina

PETITIONERS’ EXHIBIT B-3

PRE-SUIT REQUESTS FOR PRODUCTION

A. Instructions

B. Definitions

The following words have the following meanings, unless the context requires otherwise:

2. “Helena,” “You,” and “Your” collectively mean and refer to the above-named entity on whom these requests have been served, and any person acting on its behalf.

3. “Mr. Stromberg” and “Emory Stromberg” collectively mean and refer to Mr. Emory Stromberg, located at 1721 County Road 368, Taylor, Texas 76574.

4. The term “Property” is defined in Petitioners’ Verified Petition for Pre-Suit Discovery, and any supplements or amendments thereto, and refers to the tract of land where the crop dusting incident took place in Williamson County, Texas.

5. The term “document” is used herein in its broadest sense to include any medium upon or with which information is recorded or preserved which belongs to, or is in or subject to the possession, custody, or control of, any of the parties named hereinabove, by whomever generated or received, including without limitation: writings; printings; drawings; graphs; charts; notes; typewritings; photographs; slides; motion pictures; videotapes or cassettes; phonograph records; tape, video or other mechanical recordings; computer records, information storage devices, disks, or printouts; brochures; pamphlets; maps; surveys; calendars; contracts; interoffice communications; telephone recordings; ledgers; books; statements of account; journals; notices; letters; catalogs; canceled checks; bank statements; invoices; bills; diaries; purchase orders; memoranda of telephone communications; telegrams; telexes or “TWX’s”; telecopies; drafts or preliminary versions of the foregoing; communications to or from any governmental or law enforcement sub division, officer, or agency; and, any other instrument, writing, recording, or data compilation of any nature whatsoever, including any carbon, photographic, microfilm, or other type of copy of such items, if such copy is different from the original by reasons of any markings, additions, commentaries, revisions, deletions, or substitutions. The documents requested include any responsive data or information that exists in electronic or magnetic form and any such data or information should be produced in the electronic or magnetic form in which it exists.

6. The term “person” as used herein shall mean and include an individual, sole proprietorship, association, firm, partnership, joint venture, corporation, board, committee, agency, commission, or any other legal entity of any type for any purpose, whether public or private.

7. The terms “relating,” “related,” “reflecting,” or “evidencing,” when used in referencing a certain subject or thing as used herein, shall mean and include to reflect, to evidence, to mention, to discuss, to describe, to explain, to embody, to constitute, or to include that subject or thing.

8. The term “or” as used herein shall mean and include “and” or “and/or.” 9. The term “all” as used herein shall mean “any” and “all.”

10. The term “including”, as used herein, shall mean “including, but not limited to.”

11. The terms “fact” and “facts” as used herein shall include, without limitation, every relevant matter, occurrence, act, event, transaction, occasion, meeting, document, instance, circumstance, recitation, writing, or other happening.

12. The term “communication” as used herein is used in its broadest sense and shall mean oral conversations, whether telephone or face-to-face, discussions, meetings, conferences, speeches and hearings, written communications, whether letter, facsimile, or electronic transmission, and internal and external communications, and shall include both word and visual communication of any kind whatsoever.

13. The term “Unknown Pilot” is defined in Petitioners’ Verified Petition for Pre-Suit Discovery.

14. The term “Relevant Time Frame” as used herein shall mean from February 1, 2024 to the present.

15. Certain other terms may be defined within the requests for documents herein.

C. Requests for Production

Response:

Request for Production No. 2: Produce all documents and communications between you and Mr. Stromberg during the Relevant Time Frame regarding the Property, work to be performed on the Property, and concerning the events of February 20, 2024 as set forth in Petitioners’ Verified Petition for Pre-Suit Discovery.

Response:

Request for Production No. 3: Produce all documents evidencing the sale (i.e. tickets, receipts, etc.) of any chemicals or products generally intended for or related to crop-dusting during the Relevant Time Frame to the Unknown Pilot.

Response:

Request for Production No. 4: Produce copies all associated labels, safety data sheets, and other information regarding health and safety warning associated with any chemicals or products generally intended for or related to crop-dusting sold to the Unknown Pilot during the Relevant Time Frame.

Response:

Request for Production No. 5: Produce all documents evidencing the sale (i.e. tickets, receipts, etc.) of any chemicals or produced generally intended for or related to crop-dusting during the Relevant Time Frame to Mr. Stromberg.

Response:

Request for Production No. 6: Produce copies all associated labels, safety data sheets, and other information regarding health and safety warning associated with any chemicals or products generally intended for or related to crop-dusting sold to the Unknown Pilot during the Relevant Time Frame.

Response:

EXHIBIT B-4

PETITIONERS’ EXHIBIT B-4

CAUSE NO. _______________________

IN RE: NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

IN THE DISTRICT COURT 395th JUDICIAL DISTRICT WILLIAMSON COUNTY, TEXAS

PETITIONERS’ PRE-SUIT

DEPOSITION ON WRITTEN QUESTIONS TO HELENA AGRI-ENTERPRISES, LLC

To: Helena Agri-Enterprises, LLC, c/o C. T. Corporation System, as registered agent, 1999 Bryan St., Suite 900, Dallas, Texas 75201-3136

PLEASE TAKE NOTICE that under Texas Rule of Civil Procedure 200, Petitioners, Nickolas Putman (“Putman”), Robert Schubert (“Schubert”), and Matterhorn Express Pipeline, LLC (“Matterhorn” and collectively with Putman and Schubert as the “Petitioners”), will take the deposition by written questions of an authorized representative or custodian of records for Helena Agri-Enterprises, LLC (“Deponent”), pursuant to the Court’s authorization of pre-suit discovery in the above referenced cause, at __:00 __.m. on _______________ __, 2025, at the offices of ROSS MOLINA OLIVEROS, PC, 4118 Pond Hill Road, Ste. 100, San Antonio, Texas, or on a date and at a location mutually agreed upon by the Deponent and Petitioners. Deponent will be required to answer the questions listed in Exhibit B, attached hereto and made a part hereof before a certified court reporter authorized to take depositions in Texas.

Respectfully,

ROSS MOLINA OLIVEROS, P.C.

4118 Pond Hill Road, Suite 100 San Antonio, Texas 78231

(210) 249-3200 – Telephone (210) 249-3201 – Facsimile

By: /s/ Ramon A. Molina

Ramon A. Molina, Attorney-in-Charge

State Bar No. 24032872

ramolina@rmolawfirm.com

Andrew Stephens

State Bar No. 24082559

astephens@rmolawfirm.com

ATTORNEYS FOR PETITIONERS,

NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

PETITIONERS’ EXHIBIT B-4

CERTIFICATE OF SERVICE

I hereby certify that on this ___ day of __________________2025, this document was served by the method indicated, pursuant to Rule 21a of the Texas Rules of Civil Procedure:

Helena Agri-Enterprises, LLC: c/o C. T. Corporation System, as registered agent 1999 Bryan St., Suite 900 Dallas, Texas 75201-3136

FIRST CLASS MAIL RRR#

/s/ Ramon A. Molina

Ramon A. Molina

PETITIONERS’ EXHIBIT B-4

EXHIBIT “A”

Definitions and Instructions for Written Questions under Exhibit “B” The following words have the following meanings, unless the context requires otherwise:

2. “Helena,” “You,” and “Your” collectively mean and refer to the above-named entity on whom these requests have been served, and any person acting on its behalf.

3. “Mr. Stromberg” and “Emory Stromberg” collectively mean and refer to Mr. Emory Stromberg, located at 1721 County Road 368, Taylor, Texas 76574.

8. The term “or” as used herein shall mean and include “and” or “and/or.”

9. The term “all” as used herein shall mean “any” and “all.”

10. The term “including”, as used herein, shall mean “including, but not limited to.”

13. The term “Unknown Pilot” is defined in Petitioners’ Verified Petition for Pre-Suit Discovery.

14. The term “Relevant Time Frame” as used herein shall mean from February 1, 2024 to the present.

15. Certain other terms may be defined within the requests for documents herein.

PETITIONERS’ EXHIBIT B-4

EXHIBIT “B”

CAUSE NO. _______________________

IN RE: NICKOLAS PUTMAN, ROBERT SCHUBERT, and MATTERHORN EXPRESS PIPELINE, LLC

IN THE DISTRICT COURT ___ JUDICIAL DISTRICT WILLIAMSON COUNTY, TEXAS

Written Questions:

1. Please state your full name, occupation, and address.

Response:

_________________________________________________

2. Are you of sound mind, capable of answering these questions, signing the verification, and personally acquainted with the facts therein?

Response:

_______________________________________________________________________ _________________________

3. Please state the full name, occupation, employer, address, and any other available contact information (i.e. email, phone number) for the Unknown Pilot.

Response:

_______________________________________________________________________

4. Please briefly summarize the substance of any communications you had with the Unknown Pilot during the Relevant Time Frame concerning: (1) the events of February 20, 2024 as set forth in Petitioners’ Verified Petition for Pre-Suit Discovery and/or (2) the sale of any products to the Unknown Pilot that are generally intended for or related to crop-dusting.

Response:

_______________________________________________________________________

5. Please briefly summarize the substance of any communications you had with Mr. Stromberg during the Relevant Time Frame concerning: (1) the events of February 20, 2024 as set forth in Petitioners’ Verified Petition for Pre-Suit Discovery and/or (2) the sale of any products to Mr. Stromberg that are generally intended for or related to crop-dusting.

Response:

_______________________________________________________________________

6. Please identify the chemicals or products sold to the Unknown Pilot during the Relevant Time Frame for use on the Property to treat crops via crop-dusting. Please include, as part of Your Response, any available health and safety related information or warnings for any identified chemicals or products.

Response:

_______________________________________________________________________

7. Please identify the chemicals or products sold to Mr. Stromberg during the Relevant Time Frame for use on the Property to treat crops via crop-dusting. Please include, as part of Your Response, any available health and safety related information or warnings for any identified chemicals or products.

Response:

_______________________________________________________________________

8. Please identify the chemicals or products used on the Property to treat crops via crop dusting during the Relevant Time Frame, regardless of whether said chemicals or products were purchased during the Relevant Time Frame. Please include, as part of Your Response, any available health and safety related information or warnings for any identified chemicals or products.

Response:

_______________________________________________________________________

9. Please identify any person You have communicated with concerning the events of February 20, 2024 as set forth in Petitioners’ Verified Petition for Pre-Suit Discovery. Please include, as part of your Response, the contact information for person identified as well as a brief description of the general substance of any communications.

Response:

_______________________________________________________________________

SIGNED the _____ day of ________________, 2025.

__________________________________

Name of Deponent

PETITIONERS’ EXHIBIT B-4

VERIFICATION

Before me, the undersigned notary, on this day, appeared ______________, a person whose identity is known to me. After I administered an oath to _____________, he testified:

“My name is _____________. I am capable of making this verification. I verify that the responses contained herein are true and correct to the best of my knowledge.”

SWORN TO AND SUBSCRIBED before me by _____________, on this _______ day of __________________, 2025, to certify which witness my hand and official seal.

________________________________

Notary Public, State of Texas

Printed name:

____________________________

Commission Expires

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.

Ronee Gomez on behalf of Ramon Molina

Bar No. 24032872

rgomez@rmolawfirm.com

Envelope ID: 101449430

Filing Code Description: Petition

Filing Description: Petitioners' Verified Petition for Pre-Suit Discovery -EV# 101449430

Status as of 5/30/2025 4:00 PM CST

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