RETRN

CAUSE NO. __18-6796-393_____
JOHN T. THORNGREN
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IN THE DISTRICT COURT
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OF DENTON COUNTY, TEXAS
v.
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DENTON COUNTY APPRAISAL DISTRICT
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__393rd___JUDICIAL DISTRICT
PLANTIFF’S ORGINAL PETITION
JOHN T. THORNGREN, INDIVIDUALLY, AND AS OWNER OF PROPERTY LOCATED
AT 203 GOTCHER, LAKE DALLAS, TEXAS 75065, DENTON COUNTY and for cause of
action would respectfully show the court as follows:
I. DISCOVERY CONTROL PLAN
1.1 Pursuant to Tex. R. Civ. P. 190.4, plaintiff moves the court for a Level 1 Discovery
Control Plan.
II. PARTIES
2.1 Plaintiff is a Texas resident in Denton County residing at 514 N. Garza, Shady
Shores, Texas 76208. Plaintiff’s mailing address is P.O. Box 718, Lake Dallas, Texas 75065.
2.2 Denton County Appraisal District is a governmental entity located at 3911 Morse
Street, Denton, TX 76208.
III. VENUE AND JURSIDICITON
3.1 Venue is proper in Denton County, Texas under Texas Civil Practice and Remedies
Code § 15.002(a) (1-3) because all or a substantial part of the events or omissions giving rise to
the claims made in the basis of this lawsuit occurred in Denton County, Texas and because the
defendant resides and operates in Denton County.
IV. FACTUAL BACKGROUND
4.1 On June 6, 2018 the Appraisal Revue Board, hereinafter referred to as ARB, for the
Denton County Appraisal District, hereinafter referred to as DCAD, ruled to uphold a market
value of $ 94, 129 for a vacant lot at 203 Gotcher, Lake Dallas, Texas, Denton County, and said
2018 market value increased last year’s market value by $ 52,729 from its value in 2017 of
$ 41,400.
4.2 The $ 41,400 market value established for last year, 2017, was determined from an
Arbitration Case in 2016 where plaintiff prevailed with evidence showing the DCAD used
incorrect comparable sales data from a distinctly different area far removed from 203 Gotcher
and also showed DCAD displayed lower values for identical property across the street from 2013
Gotcher as well as that for a family trust on commercial property nearby in Lake Dallas.
4.3 In March, 2016, the DCAD changed the appraisal formula for land on Gotcher street.
The property across the street from 203 Gotcher as noted in 4.2 saw its appraisal jump from
$ 50,000 to $ 83, 817. Note that this total increase represents a jump in the land from $ 40,800
to $ 50,000, and the house from $9,200 to $ 21,417. However, by 11/9/2016, the same year, this
increase was reduced to $62,470. This total decrease represents a return to the 2015 land value
and a reduction in the house to an appraised value of $ 340.00. The house at that time was being
rented, and all of this was presented to the DCAD in the arbitration case noted in 4.2, and DCAD
did not made any corrections to the $ 340 appraised house which still has the same value in 2018
and has been remodeled and rented.
4.3 Gotcher is a one block long street given the neighborhood name, Gotcher Addition.
There are 3 vacant lots, 5 businesses, 7 residential houses, the American Legion, a Bar and a
park, but the DCAD in 2018 arbitrarily decided that Gotcher Addition was Commercial in
Transition and raised all property market values to $ 3.00/sq ft regardless of current zoning,
regardless of the fact that there has been NO commercial activity in Gotcher Addition for
several years, and again showing a lower value of $ 1.60/sqaure foot in favoritism for the same
property noted in 4.3 instead of the $ 3.00/square foot on every other property in Gotcher
Addition.
4.4 In the ARB Hearing on June 7, 2018, the DCAD is noted as using the same
comparable sales data from the same distinctly different neighborhood as noted in 4.2
4.5 The property across the street from plaintiff as noted in 4.3 has obtained permission
from the City of Lake Dallas to accommodate thirteen Tiny Homes which plaintiff feels will
degrade the value of his property, said property being an approximate ¾ acre residential lot, tree
shaded with 6 mature pecan trees and over a dozen other large oaks that borders the Lake Dallas
Park and Library.
4.6 Plantiff has statistically determined the DCAD’s predictive methods for the Market
Value of vacant land are terribly incorrect resulting in a severe potential tax loss to the Lake
Dallas Independent School District in which plaintiff’s property is located, and plaintiff has filed
a formal protest for an audit with the Texas State Comptrollers Office on July 30, 2018.
V. CLAIM FOR RELIEF
5.1 Plaintiff seeks a judgement from the Court to require the DCAD to accept an
Appraisal Value for 203 Gotcher in 2018, hopefully around $ 1.00/square foot ($31376.27 total)
but at whatever value the Court deems fair.
REPRESENTATION FOR THE PLAINTIFF - PRO SE
PLAINTIFF ______________________________
JOHN T. THORNGREN
MAIL: P.O. Box 718
8/3/2018
Lake Dallas, Texas 75065
Tel: 940-497-0133
E-Mail: TEXANDcorp@Charter.net