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E.D. Tex. 2009).  Garofolo v. Ocwen Loan Servicing LLC , 497 S.W.3d 474, 478 (Tex. 2016)  Wood v. HSBC Bank USA, N.A. , 439 S.W.3d 585, 595 n.5 (tex. app.-houston [14th dist.] 2014, pet..
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