CITATION â PUBLICATION â C...
CITATION â PUBLICATION...
CITATION â€" PUBLICATION â€" CIVIL
(PLAINTIFF'S ORIGINAL PETITION)
CAUSE NO. DC-C202600200
NOTICE TO DEFENDANT:
“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 (42) days after the date of issuance of 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 the 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.â€
TO: ALL PERSONS CLAIMING ANY TITLE OR INTEREST IN LAND UNDER DEED HERETOFORE GIVEN TO CITY OF KEENE, AS GRANTEE, AND THE UNKNOWN MEMBERS OF MED SURGE OF NORTH TEXAS, LLC
DEFENDANT â€" GREETINGS:
You are hereby commanded to appear by filing a written answer to the Plaintiff's Petition at or before 10:00 a.m. of the Monday next after the expiration of forty-two (42) days after the date of issuance of this citation, the same being Monday, the 9TH day of JUNE, 2026, before the Honorable 18TH DISTRICT COURT of Johnson County, Texas, at the Guinn Justice Center of said County, to answer said petition, filed on the 23RD DAY OF MARCH, 2026, in this case, numbered DC-C202600200, on the docket of said court, and styled:
CITY OF KEENE VS. LLOYD THOMAS, BONNIE THOMAS, MED SURGE OF NORTH TEXAS, LLC, ALL PERSONS CLAIMING ANY TITLE OR INTEREST IN LAND UNDER DEED HERETOFORE GIVEN TO CITY OF KEENE, AS GRANTEE
A brief statement of the nature of this suit is as follows, to wit:
You are hereby notified that suit has been brought by the City of Keene, as plaintiff, against the Unknown Members of Med Surge of North Texas, LLC, and All Persons Claiming any Title or Interest in Land Heretofore Given to City of Keene relating to the property commonly known as 307 Highway 67 E., Keene, Texas 76031 (the “Propertyâ€) and more particularly described as follows:
A 0.888 ACRE TRACT OF LAND, IN THE HUGH MCCOLLUM SURVEY, ABSTRACT NO. 570, JOHNSON COUNTY, TEXAS, CONVEYED TO BONNIE ALLEN THOMAS, AS DESCRIBED IN A DEED RECORDED IN INSTRUMENT NO. 2018-35316, OFFICIAL PUBLIC RECORDS, JOHNSON COUNTY, TEXAS, (O.P.R.J.C.T.), AND BEING MORE PARTICULARLY DESCRIBED AS FOLLOWS:
BEGINNING, AT A 1/2†IRON ROD FOUND, AT THE NORTHEAST CORNER OF SAID THOMAS TRACT, AT THE NORTHWEST CORNER OF A TRACT OF LAND, CONVEYED TO ROBERT H. & BETTY J. CUPPS REVOCABLE TRUST, AS DESCRIBED IN A DEED, RECORDED IN INSTRUMENT NO. 2009-34137, O.P.R.J.C.T., IN THE SOUTH LINE OF WEST HIGHWAY 67, A 120' WIDE RIGHT-OF-WAY (R.O.W.) AND IN THE WEST LINE OF BLUE STAR DRIVE;
THENCE, WITH THE COMMON LINE BETWEEN SAID THOMAS TRACT, AND WITH SAID CUPPS TRACT, THE FOLLOWING TWO (2) COURSES AND DISTANCES;
1. S 26° 46' 16†E, A DISTANCE OF 243.45 FEET, TO A POST FOUND, AT THE SOUTHEAST CORNER OF SAID THOMAS TRACT;
2. S 56° 46' 44†W, A DISTANCE OF 163.69 FEET, TO A CAPPED IRON ROD SET, STAMPED “GSI SURVEYINGâ€, FOR THE SOUTHWEST CORNER OF SAID THOMAS TRACT, IN THE EAST LINE OF A TRACT OF LAND, CONVEYED TO ARCO TRANSPORTATION, LLC, AS DESCRIBED IN A DEED, RECORDED IN INSTRUMENT NO. 2023-20136, O.P.R.J.C.T.;
THENCE, WITH THE COMMON LINE BETWEEN SAID THOMAS TRACT, AND WITH SAID ARCO TRANSPORTATION TRACT, AND WITH THE COMMON LINE BETWEEN SAID THOMAS TRACT, AND WITH A TRACT OF LAND, CONVEYED TO ATMOS ENERGY/MID-TEX, AS DESCRIBED IN A DEED, RECORDED IN VOLUME 277, PAGE 421, O.P.R.J.C.T., CONSECUTIVELY, N 25° 08' 33†W, A DISTANCE OF 243.60 FEET, TO A CAPPED IRON ROD SET, STAMPED “GSI SURVEYINGâ€, FOR THE NORTHWEST CORNER OF SAID THOMAS TRACT, IN A CURVE TO THE LEFT, HAVING A RADIUS OF 13580.49 FEET;
THENCE, WITH THE SOUTH LINE OF SAID WEST HIGHWAY 67, AND WITH SAID CURVE TO THE LEFT, A CHORD BEARING AND DISTANCE OF, N 56° 30' 52†E, 156.81 FEET, AN ARC LENGTH OF 156.81 FEET, TO THE POINT OF BEGINNING, AND CONTAINING 0.888 ACRES OF LAND.
Plaintiff's petition is styled Cause No. DC-C202600200, City of Keene v. Lloyd Thomas, Bonnie Thomas, the Unknown Members of Med Surge of North Texas, LLC, and All Persons Claiming any Title or Interest in Land Heretofore Given to City of Keene. The Plaintiff seeks a judgment to establish that Plaintiff has superior title to the subject property.
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 the requirements of law, and the mandates thereof, and make due return as the law directs.
Issued and given under my hand and seal of said Court at office in Cleburne, Texas, ON THIS THE 29TH DAY OF APRIL, 2026.
DEAN SULLIVAN â€" DISTRICT CLERK
18TH DISTRICT COURT
JOHNSON COUNTY, TEXAS
By: /s/ Barbara Calafell, Deputy
ATTORNEY FOR PLAINTIFF(S)
JACOB M STEPHENS
IRELAN STEPHENS PLLC
2520 CAROLINE STREET
2ND FLOOR
HOUSTON TX 77004
CITATION â€" PUBLICATION â€" CIVIL
(PLAINTIFF'S ORIGINAL PETITION)
CAUSE NO. DC-C202600200
NOTICE TO DEFENDANT:
“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 (42) days after the date of issuance of 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 the 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.â€
TO: ALL PERSONS CLAIMING ANY TITLE OR INTEREST IN LAND UNDER DEED HERETOFORE GIVEN TO CITY OF KEENE, AS GRANTEE, AND THE UNKNOWN MEMBERS OF MED SURGE OF NORTH TEXAS, LLC
DEFENDANT â€" GREETINGS:
You are hereby commanded to appear by filing a written answer to the Plaintiff's Petition at or before 10:00 a.m. of the Monday next after the expiration of forty-two (42) days after the date of issuance of this citation, the same being Monday, the 9TH day of JUNE, 2026, before the Honorable 18TH DISTRICT COURT of Johnson County, Texas, at the Guinn Justice Center of said County, to answer said petition, filed on the 23RD DAY OF MARCH, 2026, in this case, numbered DC-C202600200, on the docket of said court, and styled:
CITY OF KEENE VS. LLOYD THOMAS, BONNIE THOMAS, MED SURGE OF NORTH TEXAS, LLC, ALL PERSONS CLAIMING ANY TITLE OR INTEREST IN LAND UNDER DEED HERETOFORE GIVEN TO CITY OF KEENE, AS GRANTEE
A brief statement of the nature of this suit is as follows, to wit:
You are hereby notified that suit has been brought by the City of Keene, as plaintiff, against the Unknown Members of Med Surge of North Texas, LLC, and All Persons Claiming any Title or Interest in Land Heretofore Given to City of Keene relating to the property commonly known as 307 Highway 67 E., Keene, Texas 76031 (the “Propertyâ€) and more particularly described as follows:
A 0.888 ACRE TRACT OF LAND, IN THE HUGH MCCOLLUM SURVEY, ABSTRACT NO. 570, JOHNSON COUNTY, TEXAS, CONVEYED TO BONNIE ALLEN THOMAS, AS DESCRIBED IN A DEED RECORDED IN INSTRUMENT NO. 2018-35316, OFFICIAL PUBLIC RECORDS, JOHNSON COUNTY, TEXAS, (O.P.R.J.C.T.), AND BEING MORE PARTICULARLY DESCRIBED AS FOLLOWS:
BEGINNING, AT A 1/2†IRON ROD FOUND, AT THE NORTHEAST CORNER OF SAID THOMAS TRACT, AT THE NORTHWEST CORNER OF A TRACT OF LAND, CONVEYED TO ROBERT H. & BETTY J. CUPPS REVOCABLE TRUST, AS DESCRIBED IN A DEED, RECORDED IN INSTRUMENT NO. 2009-34137, O.P.R.J.C.T., IN THE SOUTH LINE OF WEST HIGHWAY 67, A 120' WIDE RIGHT-OF-WAY (R.O.W.) AND IN THE WEST LINE OF BLUE STAR DRIVE;
THENCE, WITH THE COMMON LINE BETWEEN SAID THOMAS TRACT, AND WITH SAID CUPPS TRACT, THE FOLLOWING TWO (2) COURSES AND DISTANCES;
1. S 26° 46' 16†E, A DISTANCE OF 243.45 FEET, TO A POST FOUND, AT THE SOUTHEAST CORNER OF SAID THOMAS TRACT;
2. S 56° 46' 44†W, A DISTANCE OF 163.69 FEET, TO A CAPPED IRON ROD SET, STAMPED “GSI SURVEYINGâ€, FOR THE SOUTHWEST CORNER OF SAID THOMAS TRACT, IN THE EAST LINE OF A TRACT OF LAND, CONVEYED TO ARCO TRANSPORTATION, LLC, AS DESCRIBED IN A DEED, RECORDED IN INSTRUMENT NO. 2023-20136, O.P.R.J.C.T.;
THENCE, WITH THE COMMON LINE BETWEEN SAID THOMAS TRACT, AND WITH SAID ARCO TRANSPORTATION TRACT, AND WITH THE COMMON LINE BETWEEN SAID THOMAS TRACT, AND WITH A TRACT OF LAND, CONVEYED TO ATMOS ENERGY/MID-TEX, AS DESCRIBED IN A DEED, RECORDED IN VOLUME 277, PAGE 421, O.P.R.J.C.T., CONSECUTIVELY, N 25° 08' 33†W, A DISTANCE OF 243.60 FEET, TO A CAPPED IRON ROD SET, STAMPED “GSI SURVEYINGâ€, FOR THE NORTHWEST CORNER OF SAID THOMAS TRACT, IN A CURVE TO THE LEFT, HAVING A RADIUS OF 13580.49 FEET;
THENCE, WITH THE SOUTH LINE OF SAID WEST HIGHWAY 67, AND WITH SAID CURVE TO THE LEFT, A CHORD BEARING AND DISTANCE OF, N 56° 30' 52†E, 156.81 FEET, AN ARC LENGTH OF 156.81 FEET, TO THE POINT OF BEGINNING, AND CONTAINING 0.888 ACRES OF LAND.
Plaintiff's petition is styled Cause No. DC-C202600200, City of Keene v. Lloyd Thomas, Bonnie Thomas, the Unknown Members of Med Surge of North Texas, LLC, and All Persons Claiming any Title or Interest in Land Heretofore Given to City of Keene. The Plaintiff seeks a judgment to establish that Plaintiff has superior title to the subject property.
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 the requirements of law, and the mandates thereof, and make due return as the law directs.
Issued and given under my hand and seal of said Court at office in Cleburne, Texas, ON THIS THE 29TH DAY OF APRIL, 2026.
DEAN SULLIVAN â€" DISTRICT CLERK
18TH DISTRICT COURT
JOHNSON COUNTY, TEXAS
By: /s/ Barbara Calafell, Deputy
ATTORNEY FOR PLAINTIFF(S)
JACOB M STEPHENS
IRELAN STEPHENS PLLC
2520 CAROLINE STREET
2ND FLOOR
HOUSTON TX 77004
Posted 3 days ago
