<mark>MARA Holdings, Inc</mark>. v. Hood County, Texas — Entry #11

Case 4:25-cv-01202-O Document11-6- Filed 10/30/25 Pagelof4 PagelD 466

August 12, 2025

Hon. RON MASSINGILL
County Judge

Hood County Courthouse
100 East Pearl St
Granbury TX, 76048

RE: Application for the Incorporation of Mitchell Bend, Texas

Dear Judge Massingill,

Attached is an application for the incorporation of Mitchell Bend, Texas as a Type
B general law municipality. The application consists of a petition of more than 50
qualified voters of the proposed city, a legal description of the proposed city, an
application satisfying the legal requirements for requesting an election on the question of
incorporation and a proposed order for your consideration.

Sincerely,

Danie! S. Lakey +

so = a NO Oe ey a,
o -
- oe

UT a cS

Representative for Committee to Incorporate
Mitchell Bend


Case 4:25-cv-01202-O Document11-6- Filed 10/30/25 Page2of4 PagelD 467

THE STATE OF TEXAS §
§ ;
COUNTY OF HOOD §

APPLICATION FOR ELECTION ON THE INCORPORATION OF
THE CITY OF MITCHELL BEND, TEXAS
as a Type B General-Law Municipality

TO THE HONORABLE RON MASSINGILL, COUNTY JUDGE OF HOOD
COUNTY:

The undersigned residents of the unincorporated community of Mitchell Bend,
Texas, citizens of Hood County, Texas, all residents of the area hereinafter described, and
all qualified voters under §11.002 of the Texas Election Code, desire that Mitchell Bend
City be incorporated into a Type-B municipality, and pray that an election be ordered on
the question of the incorporation of the proposed City of Mitchell Bend, as provided in
Chapter 8 of the Local Government Code and any other applicable Statues of the State of
Texas.

Each of the undersigned is a person who has attained the age of eighteen (18)
years and who has resided within the area to be incorporated for more than thirty (30)
days next preceding the date of this application and is a qualified voter under the laws of
this state.

Pursuant to Tex. Local Gov’t Code §8.002, the undersigned constitute greater
than 50 of the qualified voters of the proposed area for incorporation.

The boundaries and plat of the proposed City of Constitution City, when
incorporated is attached to this Application and incorporated herein for all purposes and
includes therein no territory except that which is intended to be used strictly for city

purposes (See attached Exhibit B, Boundaries of Proposed City and Exhibit C, Legal

Page 1 of 2


Case 4:25-cv-01202-O Document11-6 Filed 10/30/25 Page3of4 PagelD 468

Description of Proposed City). Said territory to be incorporated contains approximately
1.97 square miles, therefore satisfying the territorial requirements of Tex. Local Gov’t
Code §5.901. The proposed city has, at this time, more than 201 inhabitants, thereby
satisfying the population requirement of Tex. Local Gov’t Code §7.001.

The name, by which the town will be known when incorporated, will be the City
of Mitchell Bend, Texas.

WHEREFORE, PREMISES CONSIDERED, the undersigned hereby apply for

the incorporation of the City of Constitution City, Texas, this 12th day of August, 2025.

Respectfully submitted,

Daniel S. Lakey

or WS ey

renee of the conte ittee to Incorporate
Constitution City

Page 2 of 2


Case 4:25-cv-01202-O Document11-6- Filed 10/30/25 Page4of4 PagelD 469

Proposed Ballot Lanquage for Constitution City Incorporation Election

PROPOSITION
Incorporation of the "City of Mitchell Bend" as a Type B, Genera! Law

Municipality.

(PROPOSICION)
(Incorporacion de la "Ciudad de Mitchel! Bend” como un Municipio de Ley

General Tipo B)

For (A Favor)
Against (Contra)