VII.
CHRONOLOGY OF CONDUCT, TRANSACTIONS, INJURIES, ENFORCEMENT & DISCOVERY
CHRONOLOGY PARAMETERS
RECORD PERIOD
2005–MAY 5, 2026
INTEGRATED EVENT TIMELINE
| EVENT ID | DATE | ACTOR | INSTRUMENT OR COMMUNICATION | DOCUMENTED EVENT | DIRECT RESULT | CLAIM LINK | SOURCE |
|---|---|---|---|---|---|---|---|
| CH-001 | 2005 | Formation-era members identified in the organizational record | CERTIFICATE OF FORMATION | 2005 ORGANIZATIONAL RECORDS | Two Sisters Dairy LLC was formed as a dairy business. | The company came into existence in 2005. Ownership later consolidated in Anastasia Anne Thiele through the January 1–2, 2012 Bills of Sale and company minutes. | ENTITY EXISTENCE | CLAIMANT AND PROPERTY FOUNDATION | E-0001 |
| CH-002 | 2012-01-01/02 | Thiele, A | BILLS OF SALE | COMPANY MINUTES | Bills of Sale conveyed all 200 outstanding membership units to Thiele, A as separate property; company Minutes recite her as owner of all outstanding units. | Anastasia Anne Thiele acquired all 200 outstanding membership units as her separate property and became the 100% owner of Two Sisters Dairy LLC. | CLAIMANT STATUS | GOVERNANCE AUTHORITY | COMPANY-OWNED INJURY | E-0001 |
| CH-003 | 2013-06-06 | Talsma, K (grantor); Thiele, A (grantee); AgTexas, PCA (vendor's-lien assignee) | WARRANTY DEED | VENDOR'S-LIEN ASSIGNMENT | $300,000 OPERATING LINE | A warranty deed conveyed land to Thiele, A; AgTexas, PCA took the vendor's-lien assignment and extended her $300,000 operating line. | The earliest institutional-credit relationship attached to the land later disposed of in 2023–2024. | ENTERPRISE RELATIONSHIP | LONGEVITY | EV-0055 |
| CH-004 | 2018-09-26 | Pelster, R (Bank of the West) | TERM-LOAN APPROVAL COMMUNICATION | Bank of the West stated that its $15,000,000 term loan was approved subject to a first deed of trust it could not obtain, its access to the land subordinate to the senior lienholder. | A two-institution collateral dependency existed over Thiele, A's land by 2018. | ENTERPRISE RELATIONSHIP | LONGEVITY | E-0002 |
| CH-005 | 2019-08-21/22 → 09-19 | Bank of the West; AgTexas Farm Credit Services, FLCA | CONSENT TO EASEMENT REQUEST AND DENIAL | DEED OF TRUST NO. 2019-05501 | Bank of the West stated that the proposed collateral transaction required AgTexas to execute the Consent to Easement. AgTexas denied the request, and the consent was not issued or executed. Twenty-eight days later, Bank of the West recorded Deed of Trust No. 2019-05501. | Bank of the West recorded its asserted collateral and easement position after the stated consent condition was not satisfied. | ENTERPRISE RELATIONSHIP | COLLATERAL CONTROL | CP/PC LINK AS CLASSIFIED IN SECTION IV | E-0003 | EV-0648 | DEED OF TRUST NO. 2019-05501 |
| CH-006 | 2020-02-16 | Talsma, K | WRITTEN EMAIL DIRECTIVE | Talsma, K asserted a written “two-of-three” governance rule over the single-member company in an email. | A non-owner asserted written decision authority over the single-member company. | GOVERNANCE AUTHORITY | ACTOR RELATIONSHIP | E-0004 |
| CH-007 | 2021-07-30 | Pelster, R (Bank of the West) | POST-MATURITY DATE ADVANCE AGREEMENT | 8:43 P.M. EMAIL | Pelster, R transmitted the $800,000 Post-Maturity Date Advance Agreement at 8:43 PM, routed to Talsma, K and Ghorbani, I rather than to Thiele, A, the named required signatory; § 8 secures her separate property; all three borrower signature lines are blank. | Collateral exposure attached to her separate property on an instrument no borrower signed. | CP-1 AS CLASSIFIED IN SECTION IV | COLLATERAL EXPOSURE | E-0005 |
| CH-008 | 2021-09-16 | AgTexas Farm Credit Services, FLCA | LOAN INSTRUMENTS (ERATH DOC 2026-02142 § 2(b)) | AgTexas extended $15,020,628 to Martins-affiliated borrowers. | Buyer-side financing began before disclosure to Thiele, A. | ENTERPRISE TIMING | BUYER-SIDE FINANCING | E-0006 |
| CH-009 | 2021-09-22 | Thiele, A; Talsma, K | DIVORCE PETITION | A divorce petition was filed, six days after the undisclosed buyer-side financing began. | The operative dispute period opened six days after the buyer-side financing began. | TRANSACTION TIMING | E-0006 |
| CH-010 | 2021-10-21 15:18/15:19 | Talsma, K; Ghorbani, I | NATIVE TEXT MESSAGES | Talsma, K sent a message referring to “189 days.” Thirty-seven seconds later, he wrote: “Sorry that one was for Isaac.” | The operator-controller communication referring to a 189-day period preceded the lender's August 2022 default notice and the later disposition calendar. | ACTOR RELATIONSHIP | AGREEMENT EVIDENCE | TRANSACTION TIMING | E-0007 |
| CH-011 | 2022-01-05 | Bank of the West | JANUARY 2022 MODIFICATION | The January 2022 Modification set a July 5, 2022 maturity for a $20,000 fee, described the O&B Farms, Inc. sale-and-buy-back structure with a $2,500,000 paydown, and executed a § 1542 release signed by Thiele, A alone. | The instrument established the July 5, 2022 maturity date, required a $20,000 fee, described an O&B sale-and-repurchase structure involving a $2,500,000 paydown, and included the identified release. | MATURITY AND DISPOSITION TERMS | PC-3 AS CLASSIFIED IN SECTION IV | EV-0631 |
| CH-012 | 2022-04-11 | Talsma, K (order); Ghorbani, I (compliance) | APRIL 11, 2022 WRITTEN INSTRUCTION AND COMPLIANCE | The owner's request for the company's books was answered “I have ordered Isaac not to provide you with any information from today on,” with same-day written compliance. | The 100% owner was excluded from the company's records; the constructive-discovery barrier began. | RECORDS CONTROL | PC-4 AS CLASSIFIED IN SECTION IV | SECTION III BARRIER | E-0008 |
| CH-013 | 2022-07-08 | Salisbury, J (Bank of the West) | POSITION-REPORT AND OPERATING-CREDIT COMMUNICATION | Salisbury stated the operating-line balance as $6,146,401.90, an increase of $1,671,504.69 over the May 31, 2022 position report; stated that the sweep had been turned off; and wrote that the content of each call was confidential. | The stated balance increased during the interruption in the monthly position-report sequence and became the amount subsequently demanded through the default and forbearance instruments. | OPERATING-CREDIT CONTROL | DEFAULT AMOUNT | CP-2 AND PC-5 AS CLASSIFIED IN SECTION IV | E-0009 | EV-0294 | EV-0300 |
| CH-014 | 2022-07-15 | Salisbury, J (Bank of the West) | INTERSTATE EMAIL | Salisbury, J wrote “this is an exit credit…” and “I think your land is held in the name of Two Sisters.” | The operating lender described Anastasia Anne Thiele's individually titled land as though it were held in the name of Two Sisters Dairy LLC while treating the credit as an exit facility. | COLLATERAL POSTURE | CP-3 AS CLASSIFIED IN SECTION IV | EV-0294 |
| CH-015 | 2022-08-09 | Bank of the West, through counsel (Riordan, M) | NOTICE OF DEFAULT AND DEMAND | FEDEX OVERNIGHT | A Notice of Default and Demand for Payment was transmitted “Via Fedex Overnight Delivery,” demanding $6,146,401.90, cure deadline August 24, 2022, to Hico, Texas and Lake Worth, Florida. | The stated balance was converted into a formal default with an August 24, 2022 cure deadline. | DEFAULT ENFORCEMENT | CP-4 AS CLASSIFIED IN SECTION IV | E-0010 |
| CH-016 | 2022-10-27/31 | Vick, G (counsel); Thiele, A | CONFIDENTIAL MARKETING AGREEMENT (DOCUSIGN 63ACC05B; 39EB65F4) | The Confidential Marketing Agreement was executed in two DocuSign versions (63ACC05B, 10/27; 39EB65F4, 10/31), pooling Thiele, A's separate property on a 50/50 basis, though her written deletion instruction of October 24, 2022 (“Easy enough. Thanks”) was accepted by counsel. | Both executed versions retained the 50/50 pooling provision after counsel acknowledged Anastasia Anne Thiele's October 24, 2022 instruction to delete it. | SELLER ALLOCATION | CONTRACT AND GOVERNANCE RIGHTS | DIRECT CAUSATION | EV-0325 | EV-0327 |
| CH-017 | 2022-10-28 | Bank of the West | MODIFICATION AND FORBEARANCE AGREEMENT | The Modification and Forbearance recited $6,146,401.90, collected a $100,000 fee, set the disposition calendar, and executed a § 11 release with a covenant not to sue. | The $100,000 fee and the disposition calendar through which the collection ran were fixed. | FORBEARANCE CALENDAR | PC-7 AS CLASSIFIED IN SECTION IV | EV-0311 |
| CH-018 | 2022-12-31 | Talsma, K | POSITION REPORT TO BANK OF THE WEST | The report valued Rogers Pit silage at $44 per ton and reported 10,776.98 tons. The record separately contains same-season buyer pricing of $88 per ton and a 20,000-ton figure in the decree exhibit. | Different quantities and unit values entered the lender, buyer, and decree records for the same identified silage. | VALUATION REPRESENTATION | PROPERTY AND COLLATERAL RECORD | EV-0344 |
| CH-019 | 2023-01-02 → 04-20 | Talsma, K (d/b/a Talsma Dairy) | ACCOUNT NO. 952877 DEPOSIT RECORD | Six cull-cow proceeds deposits totaling $633,701.36 were made into account No. 952877, titled “TALSMA, K DBA TALSMA DAIRY PAYROLL.” | $633,701.36 of cull-cow proceeds entered the operator-titled account. | PROCEEDS ROUTING | PC-9 AS CLASSIFIED IN SECTION IV | TX-006 |
| CH-020A | 2023-02-18 | Overland Stockyards; Talsma, K; Two Sisters Dairy LLC herd | HERD-AUCTION AND SETTLEMENT RECORD | The herd auction realized $5,171,994.43 from 4,402 head sold at ring. | The herd was converted to proceeds used in the subsequent operating-line payoff and transaction sequence. | HERD DISPOSITION | COMPANY PROPERTY INJURY | FINANCIAL FLOW | E-0011 | HERD-AUCTION RECORD |
| CH-020B | 2023-02-22 | Anastasia Anne Thiele; Bank of the West; AgTexas; King Title Company | HUD-1 | KING TITLE FILE 22-36290 | The 502.035-acre Heifer Ranch closed for $3,500,000. The settlement statement reported $2,778,895.49 to Bank of the West, $703,840.60 to AgTexas, and $0.00 cash to Anastasia Anne Thiele. | Anastasia Anne Thiele's separately titled property was transferred and its closing value was applied to lender payoffs while she received no closing cash. | T1 | DIRECT PROPERTY INJURY | TAX-ALLOCATION CAUSATION | FINANCIAL FLOW | E-0011 | EV-0400 | HUD 22-36290 |
| CH-021 | 2023-02-23 | Overland Stockyards (dispersal agent); BMO Bank, N.A. (administering the operating line) | WIRE TO THE OPERATING LINE | $3,710,169.69 of herd proceeds was wired to the Bank of the West operating line, reducing it to $0.00 the same day. | The operating line was retired the same day from herd proceeds. | PROCEEDS ROUTING | PC-10 AS CLASSIFIED IN SECTION IV | TX-007 |
| CH-022 | 2023-03-29 | AgTexas Farm Credit Services, FLCA (Rosipal, J) | MARCH 29, 2023 BUYER-SPECIFIC CONSENT | AgTexas issued a buyer-specific consent naming “Tony Martins… or any other entity of which Tony Martins is a principal,” preserving Thiele, A's liability, without disclosing AgTexas's own financing of that principal's entities ($15,020,628; $7,092,112.50; $8,500,000). | Her liability was preserved while the consenting institution's own financing of the named buyer's entities went undisclosed on the thread. | CONSENT GATE | CP-7 AS CLASSIFIED IN SECTION IV | EV-0647 |
| CH-023 | 2023-04-07 | 3 T Martins Farm LLC | DAIRY LEASE AND OPTIONS TO PURCHASE | 3 T Martins Farm LLC took possession of the dairy operation under the Dairy Lease and Options to Purchase, approximately fifteen months before the sale closed; rent of $70,000/month was paid to Talsma, K, none to the 100% owner. | Possession and lease income transferred to the financed transferee before any completed sale. | T2 (POSSESSION COMPONENT) | OPERATING-FACILITY INJURY | TX-010 | EV-0420 |
| CH-024A | 2024-07-25/26 | Talsma, K; Anastasia Anne Thiele; 3 T Martins Farm LLC; King Title Company | DEED | HUD-1 | KING TITLE FILE 24-39066 | The 934.143-acre dairy property closed for $10,250,000. The settlement statement reported $0.00 cash to the identified seller. | The dairy real property transferred to the Martins-affiliated buyer through the closing structure. | T2 | OPERATING-PROPERTY TRANSFER | DIRECT INJURY | E-0012 | EV-0507 | HUD 24-39066 |
| CH-024B | 2024-07-26 | Talsma, K; King Title Company; Asset Preservation, Inc. | DISBURSEMENT AGREEMENT | CLOSING DISBURSEMENT RECORD | The closing routed $963,830.47 to account No. 952877 titled “Talsma Dairy,” routed $3,814,738.56 to Asset Preservation, Inc. as qualified intermediary, and attributed $4,450,000 of the price to Klaas Talsma as seller for Form 1099-S reporting. | The creditor-pool, qualified-intermediary, and seller-allocation amounts were directed into three separately identifiable financial and tax paths. VIII | IRS & INSTITUTIONAL ENFORCEMENT. | CRED | X1031 | ALLOC | TAX ALLOCATION | FINANCIAL FLOW | EV-0505 | EV-0506 | EV-0507 | DISBURSEMENT AGREEMENT |
| CH-024C | 2024-07-29 | BMO Bank, N.A.; Martins-affiliated entities | BMO DEEDS OF TRUST | EQUIPMENT-AND-FIXTURES UCC | BMO recorded $17,000,000 in real-property debt and an equipment-and-fixtures UCC in connection with the Martins-affiliated acquisition. | The transferred dairy position became collateral for the buyer-side acquisition financing. | ACQUISITION FINANCING | § 1962(a)/(b) PATHS | FINANCIAL FLOW | EV-0519 | BMO RECORDED INSTRUMENTS |
| CH-025A | 2024-07-30 → 08-19 | Talsma, K | ACCOUNT NO. 952877 TRANSACTION RECORD | Of the $963,830.47 closing pool deposited into the account titled “Talsma Dairy,” $866,000 was withdrawn: $510,000 was applied to the identified personal judgment and $356,000 was transferred to account No. 3140. The account was reduced to $0.00. | The pool labeled for “Two Sisters Dairy — Unsecured Creditors” was removed from the receiving account and applied through the identified operator-side transactions. | CRED | PROCEEDS ROUTING | DIRECT COMPANY-PROPERTY INJURY | TX-013 | EV-0505 | EV-0521 |
| CH-025B | 2024-11-26 | Asset Preservation, Inc.; exchange and replacement-property parties | § 1031 EXCHANGE AND REPLACEMENT-PROPERTY RECORD | The exchange was completed with reported replacement value of $2,036,568 against an adjusted basis of $9,465,760. | The exchange record reflects a $7,429,192 replacement-value shortfall or loss measure. | X1031 | EXCHANGE RIGHTS | TAX AND PROPERTY INJURY | QUALIFIED-INTERMEDIARY RECORD | EXCHANGE CLOSING RECORD | TAX RECORD |
| CH-026 | 2025-07-18 | Internal Revenue Service | FORM 668(Y)(c) | NOTICE OF FEDERAL TAX LIEN | A federal tax lien was recorded on the Florida homestead. | The federal tax lien encumbered the Florida homestead and impaired title, sale, credit, and refinancing capacity. VIII | IRS & INSTITUTIONAL ENFORCEMENT. | TAXLEVY | IRS AND INSTITUTIONAL ENFORCEMENT | FORM 668(Y)(c) |
| CH-028 | 2025-10-14 | Internal Revenue Service | FORM 668-A | NOTICE OF LEVY | The IRS issued the levy associated with the disputed tax liability. | The levy initiated the collection action that resulted in the later posting and retention of $293,805.14. VIII | IRS & INSTITUTIONAL ENFORCEMENT. | TAXLEVY | IRS AND INSTITUTIONAL ENFORCEMENT | DISCOVERY EVENT | FORM 668-A |
| CH-029 | 2025-10-20 | Internal Revenue Service | CP508C | The IRS notified Anastasia Anne Thiele that it had certified seriously delinquent federal tax debt to the United States Department of State. | The certification exposed passport issuance and renewal to denial and the existing passport to possible revocation or limitation while the disputed liability remained certified. VIII | IRS & INSTITUTIONAL ENFORCEMENT. | TAXLEVY | IRS AND INSTITUTIONAL ENFORCEMENT | CONTINUING ECONOMIC AND GOVERNMENTAL CONSEQUENCES | CP508C |
| CH-030 | 2025-11 | Anastasia Anne Thiele | COMPANY, CLOSING, TAX, AND ACCOUNT RECONCILIATION | Formal reconciliation of the company accounts, closing records, tax records, and proceeds transactions began. | The reconciliation connected the creditor-pool, dual-compensation, tax-allocation, account-routing, and claimant-specific injury records. | ACTUAL DISCOVERY | SECTION III ACCRUAL RECORD | DATED RECONCILIATION RECORDS AND UNDERLYING EVIDENCE IDS |
| CH-030A | 2025-10 → 11-18 | Internal Revenue Service; Thiele, A | AMENDED RETURN | IRS ACCOUNT TRANSCRIPT | The amended return processed; it was found processable with managerial approval on November 18, 2025. | The corrected attribution entered administrative processing while collection continued. VIII | IRS & INSTITUTIONAL ENFORCEMENT. | TAXLEVY | IRS AND INSTITUTIONAL ENFORCEMENT | IRS ACCOUNT TRANSCRIPT |
| CH-031 | 2025-11-21 | Internal Revenue Service; financial institution holding the levied funds | ACCOUNT TRANSACTION RECORD | The levy proceeds of $293,805.14 posted after the identified CDP filing. | $293,805.14 of Anastasia Anne Thiele's cash and investment capital was seized and retained. VIII | IRS & INSTITUTIONAL ENFORCEMENT. | TAXLEVY | DIRECT PROPERTY INJURY | SEPARATE ENFORCEMENT LOSS | ACCOUNT RECORD | CDP FILING RECORD |
| CH-031A | 2025-11 → present | Internal Revenue Service | ACCOUNT RECORD | Interest and collection activity continued on the assessed balance; the displayed balance later read $1,084,901.36; the homestead lien and CP508C certification remain of record. | Interest and penalties continued to accrue on the assessed balance. VIII | IRS & INSTITUTIONAL ENFORCEMENT. | TAXLEVY | IRS AND INSTITUTIONAL ENFORCEMENT | ACCOUNT RECORD |
| CH-032A | 2025-11-26 | AgTexas; Martins-affiliated entities | LOAN NO. 6811410 | RECORDED FINANCING INSTRUMENTS | AgTexas refinanced the acquired position for $33,000,000. | The Martins-affiliated transferred position moved into the AgTexas refinancing structure. | REFINANCING | § 1962(a)/(b) PATHS | ENTERPRISE CONTINUITY | EV-0646 | DOCUMENT NO. 2026-02142 |
| CH-032B | 2026-01-29 | BMO Bank, N.A.; AgTexas; Martins-affiliated entities | ERATH COUNTY DOCUMENT NOS. 2026-00449 AND 2026-00450 | BMO terminated its UCC and released its deeds of trust in connection with the AgTexas refinancing. | The BMO acquisition-lien position was released as AgTexas assumed the refinanced position. | INSTITUTIONAL HANDOFF | COLLATERAL | REFINANCING | ERATH 2026-00449 | ERATH 2026-00450 |
| CH-032C | 2026-04-14 → 05-05 | AgTexas; Martins-affiliated entities | ADDITIONAL NOTES | MAY 5, 2026 MODIFICATION | AgTexas issued $55,000,000 in additional notes on April 14, 2026. By the May 5, 2026 recorded modification, the Martins-affiliated facility totaled $118,696,740.50 across ten notes and five cross-guaranteed entities. | The acquired dairy position remained inside a materially expanded, cross-guaranteed financing structure through the final recorded event. | REFINANCING | MAINTENANCE OF ACQUIRED POSITION | FINANCIAL FLOW | DOCUMENT NO. 2026-02142 | EV-0646 |
CASE PHASES
| PHASE | DATE RANGE | OBJECTIVE OR CONDITION | PRINCIPAL ACTORS | KEY EVENTS | RESULT |
|---|---|---|---|---|---|
| PHASE 01 | 2005–2020 | Ownership and operating structure: Two Sisters Dairy, LLC is formed and 100% ownership and governing authority consolidate in Thiele, A; the institutional lending and closing/accounting infrastructure attaches to her land and the operation. | Thiele, A; AgTexas Farm Credit Services, FLCA; Bank of the West; Talsma, K | CH-001–CH-006 | A two-institution collateral dependency exists over Thiele, A's land, and a non-owner has begun asserting governance authority over the company she wholly owns. |
| PHASE 02 | 2021-07 – 2022-08 | Control, financial relationships, and representations: discretionary credit exposure is created against Thiele, A's separate property; buyer-side financing begins undisclosed; the owner is locked out of the company's records; the operating-line balance is built up during an undocumented reporting gap and converted into a formal default. | Pelster, R; Salisbury, J; Zepponi, M (Bank of the West); AgTexas Farm Credit Services, FLCA; Talsma, K; Ghorbani, I | CH-007–CH-015 | A declared default and a lender-set forbearance calendar exist, built on an undocumented balance increase, while the owner remains excluded from the company's records. |
| PHASE 03 | 2022-10 – 2023-01 | Transaction and sale preparation: the pooling instrument and forbearance calendar are executed, and the operator's position report to the lender undervalues company collateral against his own contemporaneous buyer pricing. | Vick, G; Bank of the West; Talsma, K | CH-016–CH-019 | The disposition instruments and the collateral values entering it are fixed at figures the record shows to be understated against the operator's own same-season pricing. |
| PHASE 04 | 2023-02 – 2024-08 | Closing, transfers, and claimed economic injury: the Heifer Ranch and the operating facility are each compelled to disposition at $0.00 cash to seller, proceeds are routed away from the owner, and the § 1031 exchange collapses. | Thiele, A; Bank of the West; AgTexas Farm Credit Services, FLCA; Talsma, K; 3 T Martins Farm LLC; King Title Company; BMO Bank, N.A. | CH-020A–CH-025B | Both properties transfer at $0.00 cash to seller; the seller-allocation, exchange, and creditor-pool injuries accrue at the second closing. |
| PHASE 05 | 2025-07 – 2026-05 | Concealment, continuing effects, and institutional continuity: federal tax enforcement attaches to the homestead and to Thiele, A's collection account, formal reconciliation of the company's accounts opens, and the acquired position is refinanced with the prior lenders' liens released instrument-for-instrument. | Thiele, A; Internal Revenue Service; AgTexas Farm Credit Services, FLCA; BMO Bank, N.A. | CH-026–CH-032C | The tax-enforcement injury becomes economically measurable and continuing, the discovery events identified in Section III occur, and institutional continuity through 2026 is documented. |
INJURY CHRONOLOGY
| INJURY | INJURY-PRODUCING EVENT | DATE | DIRECT LINK |
|---|---|---|---|
| Dual compensation | Obligation or closing payment, as established by EV-0654 | Oct. 20, 2022 and/or July 2024 | SECTION III |
| Heifer Ranch | Closing and lender payoff | Feb. 22, 2023 | CH-020B |
| Herd proceeds | Auction and operating-line payoff | Feb. 18–23, 2023 | CH-020A–CH-021 |
| Operating dairy transfer | Possession and completed conveyance | Apr. 7, 2023–July 26, 2024 | CH-023–CH-024A |
| Seller allocation | Closing and tax allocation | July 25–26, 2024 | CH-024B |
| Creditor pool | Closing deposit and withdrawals | July 26–Aug. 19, 2024 | CH-024B–CH-025A |
| § 1031 exchange | QI transfer and replacement completion | July 26–Nov. 26, 2024 | CH-024B and CH-025B |
| Tax enforcement | Tax allocation, lien, levy, seizure, and certification | 2023–Nov. 21, 2025 | CH-026–CH-031 |
The event causing each injury, the date it became economically measurable, and the date it was discovered are stated separately in the Injury Register (VIII) and the Injury-by-Injury Accrual Record (III).
CONCEALMENT CHRONOLOGY
| ACTOR | INFORMATION WITHHELD OR OBSCURED | CONCEALING ACT | DATE | LATER RECORD THAT REVEALED IT |
|---|---|---|---|---|
| Talsma, K (order); Ghorbani, I (compliance) | Company books, accounts, and lender information | April 11, 2022 written lockout order with same-day written compliance | 2022-04-11 forward | November 2025 reconciliation records (CH-030) |
| Salisbury, J (Bank of the West) | Source and authorization of the $1,671,504.69 operating-line increase | Interruption of the otherwise-monthly position-report series during the increase | June–July 2022 | The lender's own report series (E-0009; EV-0294) |
| AgTexas Farm Credit Services, FLCA | Its financing of the eventual buyer's entities from September 16, 2021 | Nondisclosure on the March 29, 2023 consent thread naming the buyer | 2021-09-16 → 2023-03-29 | Recorded financing instruments (EV-0642; Erath Doc 2026-02142 § 2(b)); the consent thread (EV-0647) |
| Vick, G (counsel) | Survival of the 50/50 pooling provision | Acceptance of the October 24, 2022 deletion instruction without implementing it in either executed version | 2022-10-24 → 10-31 | The two executed DocuSign versions (EV-0325; EV-0327) |
| Operator-side preparers | Company tax position and attribution | The 2023 return filed 183 days late | 2024 | Filed return record; amended-return review |
DISCOVERY CHRONOLOGY
OCTOBER 14, 2025
The federal levy notice (Form 668-A) issued (CH-028).
NOVEMBER 2025Formal reconciliation of the company accounts, closing records, tax records, and proceeds transactions began (CH-030).
JUNE 14, 2026The Heifer Ranch, herd, and excluded-assets review was completed.
JULY 5, 2026The closing, qualified-intermediary, seller-allocation, and creditor-pool verification was completed.
The chronology identifies discovery of each injury separately; the governing accrual determination is stated in Section III. A later act or injury may support separately accruing additional damages; it does not revive damages caused by an earlier expired injury.