15-25-00110-CV FILED TARRANT COUNTY 348-364430-25 6/23/2025 9:44 PM THOMAS A. WILDER DISTRICT CLERK
CAUSE NO. 348-364430-25 CITY OF LAKE WORTH, TEXAS, § IN THE DISTRICT COURT § FILED IN 15th COURT OF APPEALS Plaintiff, § AUSTIN, TEXAS § 6/24/2025 9:54:24 AM v. § CHRISTOPHER A. PRINE § Clerk PLEASANTON HOUSING FINANCE § 348TH JUDICAL DISTRICT CORPORATION, A Texas nonprofit § corporation, THE TARRANT § APPRAISAL DISTRICT, and ISMAEL § GALLEGOS, JOEY MACON, MARK § PINKSTON, ZACHARY PAWELEK, § SCOTT FERGUSON, LILIAN § CASHMER, AND BRANDON HICKS, in § their official capacities as Board Members § of Pleasanton Housing Finance § Corporation, § § Defendants. § TARRANT COUNTY, TEXAS
NOTICE OF ACCELERATED APPEAL
Pursuant to Rules 25.1 and 28.1 of the Texas Rules of Appellate Procedure, Defendants
Pleasanton Housing Finance Corporation, Ismael Gallegos, Joey Macon, Mark Pinkston, Zacharay
Pawelek, Scott Ferguson, Lilian Cashmer, and Brandon Hicks, in their official capacities as Board
Members of Pleasanton Housing Finance Corporation (collectively, “Pleasanton HFC”) state
their desire to appeal the interlocutory Temporary Injunction Order Against Pleasanton HFC, the
Tarrant Appraisal District, Ismael Gallegos, Joey Macon, Mark Pinkston, Zachary Pawelek, Scott
Ferguson, Lilian Cashmer, and Brandon Hicks signed on June 3, 2025, in City of Lake Worth,
Texas v. Pleasanton Housing Finance Corporation, a Texas nonprofit corporation, The Tarrant
Appraisal District, and Ismael Gallegos, Joey Macon, Mark Pinkston, Zachary Pawelek, Scott
Ferguson, Lilian Cashmer, and Brandon Hicks in their official capacities as Board Members of
Pleasanton Housing Finance Corporation, Cause No. 348-364430-25, in the 348th Judicial District Court, Tarrant County, Texas. Defendants appeal to the Court of Appeals for the Fifteenth District
of Texas sitting in Austin, Texas.
This appeal is accelerated under Texas Rule of Appellate Procedure 28.1(a) and Section
51.014(a)(4) of the Texas Civil Practice and Remedies Code and is not “a parental termination or
child protection case or an appeal from an order certifying a child to stand trial as an adult, as
defined in Rule 28.4.” TEX. R. APP. P. 25.1(d)(6).
This appeal involves a matter: “(A) brought by or against the state or a board, commission,
department, office, or other agency in the executive branch of the state government, including a
university system or institution of higher education; (B) brought by or against an officer or
employee of the state or a board, commission, department, office, or other agency in the executive
branch of the state government arising out of that officer’s or employee’s official conduct; or (C)
in which a party to the proceeding challenges the constitutionality or validity of a state statute or
rule and the attorney general is a party to the case.” TEX. R. APP. P. 25.1(d)(9).
2 Dated: June 23, 2025 Respectfully submitted, /s/ Daniel J. Lecavalier Blake W. Stribling Texas Bar No. 24070691 Daniel J. Lecavalier Texas Bar No. 24129028 CHASNOFF | STRIBLING, LLP 1020 N.E. Loop 410, Suite 150 San Antonio, Texas 78209 Telephone: 210-469-4155 Email: bstribling@chasnoffstribling.com Email: dlecavalier@chasnoffstribling.com
Counsel for Defendants Pleasanton Housing Finance Corporation and Board Members
3 CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing has been served in compliance with the Texas Rules of Civil Procedure on this 23rd day of June, 2025, to the following counsel of record:
Wayne K. Olson James R. Evans, Jr. Tammy Ardolf LOW SWINNEY EVANS & JAMES, PLLC Marc A. Cavazos Attorneys at Law TAYLOR, OLSON, ADKINS, SRALLA 4425 South Mopac Expressway, Building 3, & ELAM, L.L.P. Suite 400 6000 Western Place, Suite 200 Austin, Texas 78735 Fort Worth, Texas 76107-3654 (512) 379-5800 (817) 332.2580 jevans@lsejlaw.com (817) 332.4740 Fax wolson@toase.com Counsel for Tarrant Appraisal District tardolf@toase.com mcavazos@toase.com
Counsel for Plaintiff City of Lake Worth, Texas
/s/ Daniel J. Lecavalier Daniel J. Lecavalier
4 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.
Rachel Feltner on behalf of Daniel Lecavalier Bar No. 24129028 rfeltner@chasnoffstribling.com Envelope ID: 102330639 Filing Code Description: Notice of Appeal Filing Description: Notice of Appeal Status as of 6/24/2025 9:04 AM CST
Associated Case Party: THECITY OF LAKE WORTH TEXAS
Name BarNumber Email TimestampSubmitted Status
Tammy Ardolf tardolf@toase.com 6/23/2025 9:44:16 PM SENT
Wayne Olson 15276900 wolson@toase.com 6/23/2025 9:44:16 PM SENT
Marc Cavazos mcavazos@toase.com 6/23/2025 9:44:16 PM SENT
Natalee Maxwell nmaxwell@toase.com 6/23/2025 9:44:16 PM SENT
Associated Case Party: THEPLEASANTON HOUSING FINANCE CORPORATION
Kim Decker kdecker@chasnoffstribling.com 6/23/2025 9:44:16 PM SENT
Rachel Feltner rfeltner@chasnoffstribling.com 6/23/2025 9:44:16 PM SENT
Christopher Schluter cschluter@chasnoffstribling.com 6/23/2025 9:44:16 PM SENT
Julie Whitson jwhitson@chasnoffstribling.com 6/23/2025 9:44:16 PM SENT
Dan Lecavalier dlecavalier@chasnoffstribling.com 6/23/2025 9:44:16 PM SENT
Blake Stribling bstribling@chasnoffstribling.com 6/23/2025 9:44:16 PM SENT
Case Contacts
Liz Hansen lhansen@lsejlaw.com 6/23/2025 9:44:16 PM SENT
Eric Ruiz eruiz@lsejlaw.com 6/23/2025 9:44:16 PM SENT
Associated Case Party: THETARRANT APPRAISAL DISTRICT
Name BarNumber Email TimestampSubmitted Status 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.
Rachel Feltner on behalf of Daniel Lecavalier Bar No. 24129028 rfeltner@chasnoffstribling.com Envelope ID: 102330639 Filing Code Description: Notice of Appeal Filing Description: Notice of Appeal Status as of 6/24/2025 9:04 AM CST
Jim Evans jevans@lsejlaw.com 6/23/2025 9:44:16 PM SENT FILED 348-364430-25 TARRANT COUNTY 6/3/2025 4:44 PM THOMAS A. WILDER DISTRICT CLERK
CAUSE NO. 348-364430-25
CITY OF LAKE WORTH, TEXAS § IN THE DISTRICT COURT Plaintiff, § § v. § § PLEASANTON HOUSING FINANCE § 348th JUDICIAL DISTRICT CORPORATION, a Texas nonprofit § corporation, THE TARRANT § APPRAISAL DISTRICT, and ISMAEL § GALLEGOS, JOEY MACON, MARK § PINKSTON, ZACHARY PAWELEK, § SCOTT FERGUSON, LILIAN § CASHMER, AND BRANDON HICKS, § in their official capacities as Board § Members of Pleasanton Housing § Finance Corporation, § TARRANT COUNTY, TEXAS Defendants. §
TEMPORARY INJUNCTION ORDER AGAINST PLEASANTON HOUSING FINANCE CORPORATION, THE TARRANT APPRAISAL DISTRICT, ISMAEL GALLEGOS, JOEY MACON, MARK PINKSTON, ZACHARY PAWELEK, SCOTT FERGUSON, LILIAN CASHMER, AND BRANDON HICKS
On June 3, 2025, the Court heard the First Amended Application for Temporary Injunction filed
by Plaintiff City of Lake Worth, Texas, against Defendants Pleasanton Housing Finance Corporation, the
Tarrant Appraisal District, and Ismael Gallegos, Joey Macon, Mark Pinkston, Zachary Pawelek, Scott
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15-25-00110-CV FILED TARRANT COUNTY 348-364430-25 6/23/2025 9:44 PM THOMAS A. WILDER DISTRICT CLERK
CAUSE NO. 348-364430-25 CITY OF LAKE WORTH, TEXAS, § IN THE DISTRICT COURT § FILED IN 15th COURT OF APPEALS Plaintiff, § AUSTIN, TEXAS § 6/24/2025 9:54:24 AM v. § CHRISTOPHER A. PRINE § Clerk PLEASANTON HOUSING FINANCE § 348TH JUDICAL DISTRICT CORPORATION, A Texas nonprofit § corporation, THE TARRANT § APPRAISAL DISTRICT, and ISMAEL § GALLEGOS, JOEY MACON, MARK § PINKSTON, ZACHARY PAWELEK, § SCOTT FERGUSON, LILIAN § CASHMER, AND BRANDON HICKS, in § their official capacities as Board Members § of Pleasanton Housing Finance § Corporation, § § Defendants. § TARRANT COUNTY, TEXAS
NOTICE OF ACCELERATED APPEAL
Pursuant to Rules 25.1 and 28.1 of the Texas Rules of Appellate Procedure, Defendants
Pleasanton Housing Finance Corporation, Ismael Gallegos, Joey Macon, Mark Pinkston, Zacharay
Pawelek, Scott Ferguson, Lilian Cashmer, and Brandon Hicks, in their official capacities as Board
Members of Pleasanton Housing Finance Corporation (collectively, “Pleasanton HFC”) state
their desire to appeal the interlocutory Temporary Injunction Order Against Pleasanton HFC, the
Tarrant Appraisal District, Ismael Gallegos, Joey Macon, Mark Pinkston, Zachary Pawelek, Scott
Ferguson, Lilian Cashmer, and Brandon Hicks signed on June 3, 2025, in City of Lake Worth,
Texas v. Pleasanton Housing Finance Corporation, a Texas nonprofit corporation, The Tarrant
Appraisal District, and Ismael Gallegos, Joey Macon, Mark Pinkston, Zachary Pawelek, Scott
Ferguson, Lilian Cashmer, and Brandon Hicks in their official capacities as Board Members of
Pleasanton Housing Finance Corporation, Cause No. 348-364430-25, in the 348th Judicial District Court, Tarrant County, Texas. Defendants appeal to the Court of Appeals for the Fifteenth District
of Texas sitting in Austin, Texas.
This appeal is accelerated under Texas Rule of Appellate Procedure 28.1(a) and Section
51.014(a)(4) of the Texas Civil Practice and Remedies Code and is not “a parental termination or
child protection case or an appeal from an order certifying a child to stand trial as an adult, as
defined in Rule 28.4.” TEX. R. APP. P. 25.1(d)(6).
This appeal involves a matter: “(A) brought by or against the state or a board, commission,
department, office, or other agency in the executive branch of the state government, including a
university system or institution of higher education; (B) brought by or against an officer or
employee of the state or a board, commission, department, office, or other agency in the executive
branch of the state government arising out of that officer’s or employee’s official conduct; or (C)
in which a party to the proceeding challenges the constitutionality or validity of a state statute or
rule and the attorney general is a party to the case.” TEX. R. APP. P. 25.1(d)(9).
2 Dated: June 23, 2025 Respectfully submitted, /s/ Daniel J. Lecavalier Blake W. Stribling Texas Bar No. 24070691 Daniel J. Lecavalier Texas Bar No. 24129028 CHASNOFF | STRIBLING, LLP 1020 N.E. Loop 410, Suite 150 San Antonio, Texas 78209 Telephone: 210-469-4155 Email: bstribling@chasnoffstribling.com Email: dlecavalier@chasnoffstribling.com
Counsel for Defendants Pleasanton Housing Finance Corporation and Board Members
3 CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing has been served in compliance with the Texas Rules of Civil Procedure on this 23rd day of June, 2025, to the following counsel of record:
Wayne K. Olson James R. Evans, Jr. Tammy Ardolf LOW SWINNEY EVANS & JAMES, PLLC Marc A. Cavazos Attorneys at Law TAYLOR, OLSON, ADKINS, SRALLA 4425 South Mopac Expressway, Building 3, & ELAM, L.L.P. Suite 400 6000 Western Place, Suite 200 Austin, Texas 78735 Fort Worth, Texas 76107-3654 (512) 379-5800 (817) 332.2580 jevans@lsejlaw.com (817) 332.4740 Fax wolson@toase.com Counsel for Tarrant Appraisal District tardolf@toase.com mcavazos@toase.com
Counsel for Plaintiff City of Lake Worth, Texas
/s/ Daniel J. Lecavalier Daniel J. Lecavalier
4 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.
Rachel Feltner on behalf of Daniel Lecavalier Bar No. 24129028 rfeltner@chasnoffstribling.com Envelope ID: 102330639 Filing Code Description: Notice of Appeal Filing Description: Notice of Appeal Status as of 6/24/2025 9:04 AM CST
Associated Case Party: THECITY OF LAKE WORTH TEXAS
Name BarNumber Email TimestampSubmitted Status
Tammy Ardolf tardolf@toase.com 6/23/2025 9:44:16 PM SENT
Wayne Olson 15276900 wolson@toase.com 6/23/2025 9:44:16 PM SENT
Marc Cavazos mcavazos@toase.com 6/23/2025 9:44:16 PM SENT
Natalee Maxwell nmaxwell@toase.com 6/23/2025 9:44:16 PM SENT
Associated Case Party: THEPLEASANTON HOUSING FINANCE CORPORATION
Kim Decker kdecker@chasnoffstribling.com 6/23/2025 9:44:16 PM SENT
Rachel Feltner rfeltner@chasnoffstribling.com 6/23/2025 9:44:16 PM SENT
Christopher Schluter cschluter@chasnoffstribling.com 6/23/2025 9:44:16 PM SENT
Julie Whitson jwhitson@chasnoffstribling.com 6/23/2025 9:44:16 PM SENT
Dan Lecavalier dlecavalier@chasnoffstribling.com 6/23/2025 9:44:16 PM SENT
Blake Stribling bstribling@chasnoffstribling.com 6/23/2025 9:44:16 PM SENT
Case Contacts
Liz Hansen lhansen@lsejlaw.com 6/23/2025 9:44:16 PM SENT
Eric Ruiz eruiz@lsejlaw.com 6/23/2025 9:44:16 PM SENT
Associated Case Party: THETARRANT APPRAISAL DISTRICT
Name BarNumber Email TimestampSubmitted Status 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.
Rachel Feltner on behalf of Daniel Lecavalier Bar No. 24129028 rfeltner@chasnoffstribling.com Envelope ID: 102330639 Filing Code Description: Notice of Appeal Filing Description: Notice of Appeal Status as of 6/24/2025 9:04 AM CST
Jim Evans jevans@lsejlaw.com 6/23/2025 9:44:16 PM SENT FILED 348-364430-25 TARRANT COUNTY 6/3/2025 4:44 PM THOMAS A. WILDER DISTRICT CLERK
CAUSE NO. 348-364430-25
CITY OF LAKE WORTH, TEXAS § IN THE DISTRICT COURT Plaintiff, § § v. § § PLEASANTON HOUSING FINANCE § 348th JUDICIAL DISTRICT CORPORATION, a Texas nonprofit § corporation, THE TARRANT § APPRAISAL DISTRICT, and ISMAEL § GALLEGOS, JOEY MACON, MARK § PINKSTON, ZACHARY PAWELEK, § SCOTT FERGUSON, LILIAN § CASHMER, AND BRANDON HICKS, § in their official capacities as Board § Members of Pleasanton Housing § Finance Corporation, § TARRANT COUNTY, TEXAS Defendants. §
TEMPORARY INJUNCTION ORDER AGAINST PLEASANTON HOUSING FINANCE CORPORATION, THE TARRANT APPRAISAL DISTRICT, ISMAEL GALLEGOS, JOEY MACON, MARK PINKSTON, ZACHARY PAWELEK, SCOTT FERGUSON, LILIAN CASHMER, AND BRANDON HICKS
On June 3, 2025, the Court heard the First Amended Application for Temporary Injunction filed
by Plaintiff City of Lake Worth, Texas, against Defendants Pleasanton Housing Finance Corporation, the
Tarrant Appraisal District, and Ismael Gallegos, Joey Macon, Mark Pinkston, Zachary Pawelek, Scott
Ferguson, Lilian Cashmer, and Brandon Hicks, in their official capacity (Defendants).
After considering the pleadings, admissible evidence, including the testimony and exhibits
admitted at the hearing, legal authority, and argument of counsel, the Court finds that the City of
Lake Worth, Texas, is entitled to the issuance of a temporary injunction; the City of Lake Worth
has asserted causes of action against Defendants; the City of Lake Worth has established a probable
right to recover against Defendants; and unless Defendants are immediately temporarily enjoined
as described below, the City of Lake Worth, Texas, will suffer irreparable injury, for which there
is no adequate remedy at law.
Temporary Injunction – Page 1 FINDINGS IN SUPPORT OF TEMPORARY INJUNCTION
1. The term “Neuhaus Lake Worth Apartments” refers to that development commonly
known as a multi-family unit apartment complex located at 6201 Azle Ave., Lake Worth, Texas
76135. The legal description of this property is:
Lot 1, Block 1, of FDG-POH LAKE WORTH JV ADDITION, LOT 1, BLOCK 1, a subdivision to the City of Lake Worth, Tarrant County, Texas, according to the Plat thereof recorded in cc# D225063225, Real Property Records, Tarrant County, Texas.
2. This Court has subject matter jurisdiction over this matter pursuant to TEX. CIV.
PRAC. & REM. CODE § 37.003 and TEX. TAX CODE § 43.01.
3. Defendant Tarrant Appraisal District’s governmental immunity has been expressly
waived by TEX. TAX CODE § 43.01.
4. The City of Lake Worth, Texas, will suffer imminent and irreparable harm if
Defendant Pleasanton Housing Finance Corporation is allowed to purchase properties in Lake
Worth, Texas, and seek full tax exemptions for those properties. Specifically, if a temporary
injunction is not entered and Defendant Pleasanton Housing Finance Corporation is allowed to
remove over a million dollars in ad valorem tax revenue from the tax rolls, this will immediately
and drastically impact Plaintiff’s fiscal budgeting and decrease the ad valorem taxes it otherwise
could have collected from these properties. There is no adequate remedy at law with regard to the
impact on city services.
IT IS THEREFORE ORDERED that the following activity is temporarily enjoined as to
the below-named Defendants, their officers, agents, employees, servants, and attorneys, and those
in active concert or participation with them who receive actual notice of this order as follows:
1. Pleasanton Housing Finance Corporation and Defendant Board Members Ismael Gallegos, Joey Macon, Mark Pinkston, Zachary Pawelek, Scott Ferguson, Lilian Cashmer, and
Temporary Injunction – Page 2 Brandon Hicks in their official capacity are prohibited from purchasing or approving the purchase of real property located in the City of Lake Worth, Texas;
2. Pleasanton Housing Finance Corporation and Defendant Board Members Ismael Gallegos, Joey Macon, Mark Pinkston, Zachary Pawelek, Scott Ferguson, Lilian Cashmer, and Brandon Hicks in their official capacity are prohibited from requesting, approving, or obtaining tax exemptions for any real property located in the City of Lake Worth, Texas, to include but not be limited to the Neuhaus Lake Worth Apartments; and
3 . The Tarrant Appraisal District is prohibited from granting tax exemptions requested by Pleasanton HFC regarding any real property located in the City of Lake Worth, Texas, to include but not be limited to the Neuhaus Lake Worth Apartments.
IT IS FURTHER ORDERED that this temporary injunction shall remain in effect until
further order of this Court or after a trial on the merits has concluded.
The City of Lake Worth, Texas, is exempt from posting a bond pursuant to § 6.002 of the
Texas Civil Practice and Remedies Code.
IT IS FURTHER ORDERED that the trial on the merits of this case is set for the
week of December 1, 2025.
Signed: June 3, 2025, at 4:39 p.m.
_____________________________________ Judge Presiding
Temporary Injunction – Page 3 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.
Envelope ID: 101576354 Filing Code Description: No Fee Documents Filing Description: TEMP INJ Status as of 6/3/2025 4:56 PM CST
Tammy Ardolf tardolf@toase.com 6/3/2025 4:44:58 PM SENT
Wayne Olson 15276900 wolson@toase.com 6/3/2025 4:44:58 PM SENT
Natalee Maxwell nmaxwell@toase.com 6/3/2025 4:44:58 PM SENT
Marc Cavazos mcavazos@toase.com 6/3/2025 4:44:58 PM SENT
Associated Case Party: THEPLEASANTON HOUSING FINANCE CORPORATION
Kim Decker kdecker@chasnoffstribling.com 6/3/2025 4:44:58 PM SENT
Lisa O'Sullivan losullivan@chasnoffstribling.com 6/3/2025 4:44:58 PM SENT
Dan Lecavalier dlecavalier@chasnoffstribling.com 6/3/2025 4:44:58 PM SENT
Blake Stribling bstribling@chasnoffstribling.com 6/3/2025 4:44:58 PM SENT
Liz Hansen lhansen@lsejlaw.com 6/3/2025 4:44:58 PM SENT
Eric Ruiz eruiz@lsejlaw.com 6/3/2025 4:44:58 PM SENT
Jim Evans jevans@lsejlaw.com 6/3/2025 4:44:58 PM SENT