ORDER NO. 16140
COUNTY ATTORNEY AUTHORIZED TO FILE A SUIT IN THE DISTRICT COURT
OF KERR COUNTY, TEXAS AND ASKING THAT A TEMPORARY RESTRAINING
ORDER BE ISSUED AGAINST THE TEXAS COUNTY AND DISTRICT RETIREMENT
SYSTEM AND JANIE BILL [4OLFRUD4
On this the 25th day of June 1985, upon motion made by Commis-
sioner Guthrie, seconded by Commissioner Holland, it was unani-
mously approved by the Court that County Attorney Gary E. Kersey
be authorized to file a suit on behalf of Kerr County in the
District Court of Kerr County, Texas, against Janie Bi11 Wolfrum,
and asking that a temporary restraining order be issued against
the TEXAS COUNTY AND DISTRICT RETIREMENT SYSTEM and asking that
a temporary restraining order be issued against JAPdIE BILL [VOLFRUM,
to enjoin the Retirement System from paying Janie Bill [dolfrum,
former Deputy District Clerk, her retirement benefits, pending
her trial for embezzlement, and restraining Janie Bill Wolfram
from receiving or spending those retirement benefits.
It is further ordered by the Court that the County Treasurer
and County Auditor be authorized to draw a voucher on the General
Fund, to reimburse Gary E. Kersey an amount of $35.00 for Sheriff's
fees paid in advance and authorizing $50.00 paid by the County
Treasurer, also for Sheriff's fees.
COUNTY OF KERR
VS.
JANIE BILL WOLFRUM
NO. ~j- ~~7-~
X
X
X
X
X
IN THE DISTRICT COURT
OF KERR COUNTY, TEXAS
~4% JUDICIAL DISTRICT
PLAINTIFF'S ORIGINAL PETITION FOR
DAMAGES AND INJUNCTION
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES the COUNTY OF KERR, State of Texas, by and through
its County Judge, Plaintiff, complaining of JANIE BILL WOLFRUM,
Defendant, and for cause would show:
I.
The COUNTY OF KERR is a governmental entity, duly formed and
existing under the laws of the State of Texas. Defendant, JANIE
BILL WOLFRUM, is an individual who may be served with process at
the Kerrville State Hospital, Kerrville, Texas.
II.
Plaintiff employed Defendant to work in various capacities,
beginning on or about April 1, 1976. On or about February 1,
1981, Defendant was employed as a Deputy District Clerk in the
office of the Kerr County District Clerk.
III.
Plaintiff would show on or about May 8, 1985 shortages in
the office of the District Clerk were discovered and such
shortages were a direct result of misapplication of cash funds by
the bookkeeper, a position occupied by Defendant until she was
terminated on May 8, 1985.
IV.
Plaintiff would further show that an audit by the accounting
firm of PRESSLAR & THOMPSON, Kerrville, Texas, covering a period
from October 1, 1984 to May 16, 1985 reflects a $25,550.20
shortage of funds.
1
V.
Plaintiff would further show that Defendant intentionally
converted all of the above monies for her benefit, without right
or authority and to the detriment of Plaintiff.
VI.
Plaintiff has been damaged in the sum of $25,550.20"as of
May 8, 1985 and should be paid this sum by Defendant, plus
prejudgment interest at the rate of ten percent (10$) per annum
from May 8, 1985 to the date of judgment.
VII.
Plaintiff will suffer irreparable harm and damage, for which
Plaintiff has no adequate remedy at law unless a Temporary
Restraining Order is issued immediately in that the TEXAS COUNTY
AND DISTRICT RETIREMENT SYSTEM has funds payable to Defendant and
will pay said funds to Defendant on or about the 25th day of
June, 1985, and upon payment of these funds to Defendant,
Plaintiff fears they will be lost to Plaintiff as shown in the
Affidavit attached. The amount of the funds is $7,481.99,
together with accrued interest.
VIII.
Plaintiff hereby joins the TEXAS COUNTY AND DISTRICT
RETIREMENT SYSTEM as a necessary party and prays that service be
had by serving said Defendant by and through its Director, Mr.
Bob Brown, at 400 West 14th Street, Austin, Texas 78701.
WHEREFORE, Plaintiff requests and prays:
(1) That a Temporary Restraining Order be issued against
Defendant RETIREMENT SYSTEM without notice to
Defendants, restraining said RETIREMENT SYSTEM, its
agents, servants and employees, from directly or
indirectly paying any funds held on behalf of JANIE
BILL WOLFRUM, to JANIE BILL WOLFRUM.
(2) That a Temporary Restraining Order be issued against
Defendant WOLFRUM, without notice, restraining
Defendant WOLFRUM, her agents, servants and employees
2
form directly or indirectly receiving, spending or
secreting any funds she may recieve from said
RETIREMENT SYSTM.
(3) That both Defendants be cited to appear and show cause
and that upon such hearing, a temporary injunction be
issued against both Defendants upon the same terms and
conditions as the above sought Temporary Restraining
orders.
(4) That upon final hearing hereof that Plaintiff have
judgment for $25,550.20; prejudgment interest of ten
percent (10~) from May 8, 1985 to date of judgment,
costs of Court, postjudgment interest pursuant by law,
that the above Defendants be ordered to pa.y the funds
requested restrained hereby to Plaintiff, and for such
other relief as Plaintiff matt' show itself entitled
i
either at law or in equity.~~
~I /
BILE®A
~•~~,SC~ n'clak_-ter--M
JUN 21 1985
MARY BROOKS
Disvict Clerk
Kert County, exa~
~~~~ ~~,
vAL\1 lj• [\la JGS
County At rney
Kerr County, Texas
317 Earl Garrett
Kerrville, Texas 78028
(512) 896-0482
Bar Card No. 11354500
3
COUNTY OF KERB
VS.
JANIE BILL WOLFRUM
No. gs .1s 7-r~
X
X
X
X
X
IN THE DISTRICT COURT
OF KERB COUNTY, TEXAS
c~ J ~ .JUDICIAL DISTRICT
Before me the undersigned authority, on this day personally
appeared RHONDA M. PHILLIPS, Affiant, and upon oath, after being
duly sworn did state that the following is true and correct and
is within Affiant's personal knowledge:
(1) That JANIE BILL WOLFRUM owes the COUNTY OF KERR the sum
of $25,550.20.
(2) That the Texas County and District Retirement System
holds a minimum amount of $7,481.00, belonging to JANIE
BILL WOLFRUM.
(3) That JANIE BILL WOLFRUM has requested that the monies
be funded directly to her.
(4) That the District and Retirement System will do so
unless a Temporary Restraining Order is issued.
(5) That JANIE BILL WOLFRUM has stated that the funds are
"her money", and that she has refused to release said
monies to the COUNTY OF KERR.
(6) That Affiant, based upon the above, fears that said
monies will be lost to the COUNTY OF KERR if a
Temporary Restraining Order is not issued.
(7) Further Affiant sayeth not.

Affiant _
IE.Pr~T ~ ('cxrn;7 v ~'.PEgSti~c'Ek~
SWORN AND SUBSCRIBED TO BEFORE ME on this ~ day of June,
1985.
~~ [ ,
Notary Public, State of Texas,
My Commission Expires: fj_~p_~y5
L, ~yti~ iJ~"~
Notary's Printed Name
1
STATE OF TEXAS
COUNTY OF KERR
This instrument was acknowledged before me on the ~~sT' day
of June, 1985 by RHONDA M. PHILLIPS.
Notar~~lic, State of Texas
My Commission Expires: ~. ~~ _ ~5
L . SAN ~E L
Notary's Printed Name
2
NO. ~ .S is '7 -~
COUNTY OF KERR X IN TBE DISTRICT COURT
X
VS. X OF KERR COUNTY, TEXAS
X
JAMIE BILL WOLFRUM X pl~_ JUDICIAL DISTRICT
VERIFICATION
STATE OF TEXAS
COUNTY OF KERR
BEFORE ME, the undersigned Notary Public, on this day `
personally appeared BILL BASKETTE, JR., Court Administrator for
the Commissioners Court of Kerr County, Texas, who being by me
duly sworn on his oath deposed and said that he is the duly
authori2ed agent for the Plaintiff in the above-entitled and
numbered cause; that he has read the above and foregoing
Plaintiff's Original Petition for Damages and Injunction, that
every statement contained therein is within his information and
belief as stated, and is true and correct.
BILL BASKETTE,
SUBSCRIBED AND SWORN TO BEFORE ME on the a/ST day of June,
1985, to certify which witness my hand and official seal.

Notary Public, State of Texas
My Commission Expires: A-~o- 8~~
L. Stan! Z7EL
Notary's Printed Name
1
N0. 55~~-'~ 7 ! i
COUNTY OF KERR X IN THE DISTRICT COURT
VS. X OF KERR COUNTY, TEXAS
JANIE BILL WOLFRUM X ?1~> _TH JUDICIAL DISTRICT
ORDER AND SHOW CAUSE
The COUNTY OF KERR, in this cause, has filed a Motion for
Temporary Injunction, and, in connection therewith, has presented
a motion for a temporary restraining order, together with its
petition and affidavits supporting the motion presented. It
appears from these papers that Plaintiff is probably entitled to
a temporary injunction and that unless the TEXAS COUNTY AND
DISTRICT RETIREMENT SYSTEM and JANIE BILL WOLFRUM, Defendants
herein, are immediately ds#-eared from paying any funds held by
the TEXAS COUNTY AND DISTRICT RETIREMENT SYSTEM to the said JANIE
BILL WOLFRUM and the said JANIE BILL WOLFRUM receiving any funds
from the TEXAS COUNTY AND DISTRICT RETIREMENT SYSTEM, they will
commit said acts before notice of hearing on the Motion for
Temporary Injunction can be served and a hearing had, and that if
the commission of said acts be not immediately restrained,
Plaintiff will suffer irreparable injury, in that Plaintiff will
lose the ability to receive said funds if Plaintiff takes
judgment in and under the original petition filed herein.
IT IS, THEREFORE, ORDERED that the TEXAS COUNTY AND DISTRICT
RETIREMENT SYSTEM and JANIE BILL WOLFRUM, Defendants in this
cause, be, and they are hereby, commanded to forthwith desist and
refrain from the following:
1. That the TEXAS COUNTY AND DISTRICT RETIREMENT SYSTEM is
ORDERED to restrain from and not to pay to JANIE BILL
WOLFRUM, any of her agents, servants and/or employees,
any funds held on behalf of the said JANIE BILL
WOLFRUM.
2. That the said JANIE BILL WOLFRUM, her agents, servants
and/or employees are hereby ORDERED to restrain from
and not to directly or indirectly receive, spend or
1
N
secrete any funds that may be received from the said
TEXAS COUNTY AND DISTRICT RETIREMENT SYSTEM;
from the date of entry of this order until and to the tenth
(10th) day after entry or until further order of this Court.
IT IS FURTHER ORDERED that the TEXAS COUNTY AND DISTRICT
RETIREMENT SYSTEM and JANIE SILL WOLFRUM, Defendants, appear
before me on the ~ °~! day of ~~" _ 1985, at
• ~ 0 ~' ~' o'clock in the courtroom of the '~'~` ~J dicial
District Court of Kerr County, Texas, situated in Kerrville, Kerr
County, Texas, then and there to show cause, if any there be, why
a temporary injunction should not be issued as requested by
Plaintiff. The Clerk of the Court is hereby directed to issue a
Show Cause Notice to each Defendant to appear at the temporary
injunction hearing.
The Clerk of the above entitled court shall forthwith, on
the filing by Plaintiff of the bond hereinafter required, and
upon the proving of the same according to law, issue a temporary
restraining order in conformity with the law and the terms of
this order.
This Order shall not be effective unless and until Plaintiff
executes and files with the Clerk a bond, in conformity with the
law, in the amount of $_ ~ 0 O. 0 O
SIGNED this _'2'~ day of June, 1985, at ~' O 3
o'clock P.M.
_~~ ~~~~_
Judge Presiding, 216th
Judicial District Court,
Kerr County, Texas
FILED
eoo~ r~,.
2
ar ~ a~wc~ ~ ~ r
J,U,.N~,21~ 198
~ L.
,ti""~_
Krr Oouib.Td
by
COUNTY OF KERB
VS.
JANIE BILL WOLFRUM
No. ~S- Ise-{=
X
X
X
X
X
IN THE DISTRICT COURT
OF KERR COUNTY, TEXAS
2~ JUDICIAL DISTRICT
BOND FOR TEMPORARY RESTRAINING ORDER
STATE OF TEXAS
COUNTY OF KERR
In Cause No. a S "~ s ~"~, in the District Court bf Kerr
County, Texas, entitled COUNTY OF KERR VS. JANIE BILL WOLFRUM, we
the undersigned COUNTY OF KERR, as Principal, and GARY E. KERSEY
and BILL BASKETTE, JR. as Sureties, acknowledge ourselves bound
to pay to the TEXAS COUNTY AND DISTRICT RETIREMENT SYSTEM and
JAN,I[E BILL WOLFRUM, jointly and severally, the sum of
J D 0.0 0 conditioned that the said COUNTY OF KERR
will abide the decision which may be made in theaforesaid Cause,
and that it will pay all sums of money and costs that may be
adjudged against it if the Temporary Restraining Order issued on
3une ~, 1985, in the aforesaid Cause, enjoining the TEXAS
COUNTY AND DISTRICT RETIREMENT SYSTEM and JANIE BILL WOLFRUM,
shall be dissolved in whole or in part.
COUNTY OF KERR, PRINCIPAL
By: Bill Baskette / Jr.
Court Adminis rator for
Commissiners Court of
Kefr County, Texas
i
~~ ~ /
. CL
A E. K SEY, Surety
.~/_ ~ //~
BILL BASKETTE, JR/., Surety
Approved June ~, 1985.
~]T~~~~~
Ai .3d ~~• ~ P ,_ .•,
JUN 2 1 1985
MARY b+~ ..~
D Yr!S.
~Km C us ~~-~[.~[/V
r~
~~~ ~~~
RY B O KS, District Clezk
aib. Judicial District of Texas
1
I~RK'S COPY
PLEASE RETURN
COUNTY OF KERR X IN THE DISTRICT COURT
VS. X OF KERR COUNTY, TEXAS
JANIE BILL WOLFRUM X ~_TH JUDICIAL DISTRICT
TEMPORARY RESTRAINING ORDER AND SHOW CAUSE ORDER
T0: JANIE BILL WOLFRUM
In Cause No. 85-157-A _ in the District Court .of Kerr
County, Texas, 216th_th Judicial District, in which the COUNTY
OF KERR is the Plaintiff and the TEXAS COUNTY AND DISTRICT
RETIREMENT SYSTEM and JANIE BILL WOLFRUM are Defendants, the
Plaintiff, having filed a Motion for a Temporary Injunction and
in connection therewith, a motion that you be restrained as
hereinafter set forth, the Court has duly made its order that the
Plaintiff is entitled to such relief, in that it appears to the
Court that unless you are immediately deterred from the
commission of the acts hereinafter prohibited, you will commit
said acts before notice of the hearing on the Motion for a
Temporary Injunction can be served and the hearing had, and if
the commission of said acts be not immediately restrained,
Plaintiff will suffer irreparable injury, in that you will waste,
spend or secrete said funds, and upon such occurrence, said
Plaintiff will suffer irreparable damage or injury.
NOW, THEREFORE, YOU ARE COMMANDED forthwith to desist and
refrain from directly or indirectly receiving, spending or
secreting any funds you may receive from the TEXAS COUNTY AND
DISTRICT RETIREMENT SYSTEM, from, until and after the date of
July 1st 1985.
The motion of Plaintiff for a temporary injunction has been
set for hearing before the 216th District Court of Kerr County,
Texas, on July 1st 1985, at 1:30 in the
courtroom of the abovementioned Court in the Courthouse of Kerr
County, in the City of Kerrville, Texas.
ISSUED on this 21 day of June, 1985, at 4:45
~~
J U N 2 4 1985 1
MAfaV ©F~OOKS
p,,:,m~ cyan,
K rr CAUn
M ~~'v

o'clock p.m., to certify which witness my hand and seal of
office. l' _ ~n~,,
HyC~ )IJ~C,{~~ Deputy -~~'~s1L~=4-"i
_ MARY BRggKS, DISTRICT CLERK
216th Judicial District Court
of Kerr County, Texas
This writ is returnable on the Monday next after the
expiration of twenty (20) days from date of service hereof.
q ~ 1 :R q r t~ :, i, i. dr A i i' x, $ 6 ~~ i ~ ~ F# '. -s ~. f ~ ~,
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16-2t tU-CITATION-PERSONAL SERVICE-DISTRICT OR COUNTY COURT 1318?1 Class 0-2"~
THE STATE OF TEXAS
CITATION
To Janie Bill Wolfrum __
Defendant-, in the hereinafter styled and numbered cause:
YOU ARE HEREBY COMMANDED to appear before the 216th Dist . Court
of Kerr County, Texas, to be held at the courthouse of said County in the City of
Kerrville _~ Kerr _~- ~ _ County, Texas, by fi]ing a written answer to the
petition of plaintiff- at ur before II} o'clock 9.?sI. of the Monday nc.~t uftc•r thu expiration of 20 clays after the
date of service hc~rcu£, a copy of which accompanies this citation, in cause number -_8;Z 157-A --, styled
COTTNT OF KFRR __ _~_ __ ,Plaintiff-,
vs. .TANTR RTT.T• WnLF'RTiM i _._ ,Defendant-,
filed in said court on the -21 day of -_ June _-_, 19 85
If this citation is not served within 90 days after date of its issuance, it shall he returned unnerved.
ISSUED ANll GIVEN FNllI?R DIY HANll AND SI? ~1, of said Coma at office, this the 21 day of
June 19_$x.
MARY BROOKS
T)i Rim nt Clerk of Kerr County, Texas
Ry --~..'Y~ ~ Z ~~ ~~~~ ~~ Deputy.
Came to hand on the -_21 __ day of
OPFICEft'S RETURN
19~~, at ~~ock ~~.M.
Hart Graphics-AYSllll, Texaz
c"
F~ , ~ K~ SRN
°Eseauted at ~ ~~~~~`(+"-"~`- ,within the County oI ~eTr ~, at ~ ~~ o'clock ~. M.
on the ~~-~ day of O ., 19 ~J , by delivering to the within named _
Janie Bill Wolfrum
-- ----- --- - -- --- -- ----.-, in person,
a trot copy of this citation Gl,+;cthcr with the accompanying copy of tbo potitinn, havin Q_ first attnchcd much copy of
such petition to such copy of citation and indorsed on such copy of citation ibe data of delivery.
°Not executed, the diligence used hi execute being -. ----- _.. _._
;fur the following re:uon ___._---_
-- ____, the defendant muy bo Found _
The distance actually traveled by me in serving such process was
follows:
Fur serving this citation
For mileage .
Total fees .
TO CERTIFY \VHICH WITNESS \4Y HAND OFFICIALLY.
~ ~p~ILED
At...l~ O'cloch ~' Y
.! U N 2 4 1985
MARY BROOKS
Dlslricl Clerk
Ke r Cwn Ttl ~9Jy
M
>ntrike if nut ap ilicabl°
_ miles, and my fees are as
- _~- '- ~ Sheri$ Account
No.
6-
CLIFF GREESON
Kerr
Sheri$
Countable

~~,, ~ ~ ~ Z Cuuntv, Texas
I3y _4%'?~~t~1.__~!1 ~-fa~ _ Deputy.
For Clerk's Use
"Paxe~ -- _.
Return rewrded
RETURN TO COURT COPY
ORDER N0. 16140
COUNTY ATTORNEY AUTHORIZED TO FILE
A SUIT IN THE DISTRICT COURT OF
KERR COUNTY, TEXAS AND ASKILdG
THAT A TEMPORARY RESTRAINING ORDER
BE ISSUED AGAICdST THE TEXAS COUNTY
& DISTRICT RETIREMENT SYSTEM AND
JANIE BILL WOLFRUM
6-25-1985
Vol. Q, Page 91
0 CoV
Sl ~ h~'y O
DANNY R. EDWAHDS
COUNTY JUDGE, KERR COUNTY
KERRVILLE, TEXAS 78028
PHONE: 512-257-6711
September 13, 1990
Attorney General of Texas
Collections Division
P. O. Box 12548 -Capitol Station
Austin, Texas 78711-2548
Re: Sales and Use Tax Suit Authorization
Taxing Authority of Kerr County, Texas
Dear Sir:
Enclosed please find a copy of our Commissioners' Court Order No. 19018
giving approval for David Motley, County Attorney to sign sales and use tax
suits for Kerr County. Also enclosed is the form showing Mr. Motley's
signature as the taxing authority for Kerr County, Texas.
If you need any additional information, please advise.
Sincerely,
DANNY R. EDWARDS
County Judge
DRE/Ir
Attorney General of Texas
Collections Division
P. O. Box 12548
Capitol Station
Austin, Texas 78711-2548
Re: Sales and Use Tax Suit Authorization
Taxing Authority of Kerr County, Texas
Dear Sirs:
The above identified taxing authority hereby authorizes the Attorney
General of Texas to include it as a Plaintiff in any suit brought by
the Attorney General on behalf of the State of Texas to collect sales
and use taxes, penalties and interest, which may be owed to this
taxing authority.
It is understood and acknowledged that this authorization will
continue in effect unless written revocation is delivered to the
above address by certified mail.
TAXING AUTHORITY OF KERB COUNTY, TEXAS
tout fferKu~1

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SENDER-INSTRUCTIONS
Print your name: eddrou and ZIP Cods
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• Complete Items. t, 2..3, and 4 an the
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700 MAIN STREET -COUNTY COURTHOUSE
KERRVILLE TX 78028
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