Michael Thoams Paul

Plaintiff

V. COMAL

Curtis Crosser

Defendant

Plaintiff's Original Petition Trespass to Try Title

Plaintiff Michael Thomas Paul files this petition Trespass to Try Title against the Defendant

Curtis Crosser and would show the court as follows.

Paul intinds to conduct

Paul is an individual who resides in Comal County Texas.

2. Defendant, Curtis Crosser is an individual who resides in The Highlands, Texas.

And may be served eith process of service at his home residence located at 310 Greenbow Ln,

Highlands, TX 77562-2104
 Comal

5. Paul purchased a 1990 Rey Craft bassbost model V-159 on August, 28, 2021 from

Brigham Rushing of Baytown, Texas after responding to an offer for sale on the Facebook Marketplace.

Paul paid $800 cash for the boat in AS IS condition and was given a bill of sale from Mr. Rushing.

Upon learning that a title is required contacted Mr. Rushing who said he bought the boat from Safe

Tech Services in 2019 that was without title at the time.

6. Paul found the titled owner Curtis Crosser using facebook and contaced him by

facebook messenger requesting he sign a release of title. Crosser stated he never sold the boat and

wanted it returned. Paul asked Crosser how it was he lost his boat and now 3 years latter wants it back.

Crosser would not naswer the question but would ask who is the titled owner stating he is and wants

his boat back. Paul searched and found no report was ever made by Mr Cosser that his boat was stolen

or missing. After calling the Harris county Sheriff Paul was instructed to file in court for a declartation

of ownership providing an order granting title rights to the vesel.

V. Complaint

Count one

7. Sec. 22.001. TRESPASS TO TRY TITLE. (a) A trespass to try title action is the

method of determining title to lands, tenements, or other real property. Plaintiff claims Adverse

possession.
 8. Accordinly, Plaintiff seeks a judicial determination awarding him sole ownership of the

property persuant to Texas Civil Practice and Remedies Code - CIV PRAC & REM § 16.024.

VI Request For Relief

For the resons set forth herein, Paul respectfully requests that the Defendant be

cited to appear and answer, and that upon final hearing, the court award:

A A judgement judgement as requested herein.

B. Judgement in favor of Paul for all costs of court in this preceeding.

C. Judgement in favor of Paul for it's reasonable and necessary attorney's fees

in the prosecution of this action, and:

D. All such other and further relief, at law or in equity to which Paul may be

justly entitled.

Respectfully Submited,
Verified by PDFFiller

09/16/2021
By, Michael Thomas Paul
9123 Easy Street
San Antonio, Texas 78266
(210) 685-9521
mtp8389@gmail.com
 x
Michael Thomas Paul mtp8389@gmail.com MICHAEL THOMAS PAUL
9123 Easy Street (210) 685-9521

San Antonio, Tx 78266 CURTIS K, CROSSER

Verified by PDFFiller

09/16/2021