, ‘may be presumed to have taken judicial notice of the records in the court's file without any request being made and without an announcement in the record that it has done so.’ ‘[W]e may presume that a trial court took judicial notice of the file even if there is no record that the trial court did so expressly.’ " (internal citations omitted) (first and second quotes from In re J.E.H. , 384 S.W.3d 864, 869–70 (Tex. App.—San Antonio 2012, no pet.), and third from Iqbal v. Federal Nat'l Mortg. Ass'n , No. 03-15-00667-CV, 2017 WL 2856737, at *3 (Tex. App.—Austin June 29, 2017, pet. denied) (mem. op.) )).

Furthermore, a trial court is "presumed to judicially know what has previously taken place in the case tried before it," and where the record is silent (as here), "may be presumed to have taken judicial notice of the records in the court's file without any request being made and without an announcement in the record that it has done so." In re J.E.H., 384 S.W.3d 864, 869-70 (Tex. App.—San Antonio 2012, no pet.) (citations omitted); see also Iqbal v. Federal Nat'l Mortg. Ass'n, No. 03-15-00667-CV, 2017 WL 2856737, at *3 (Tex. App.—Austin June 29, 2017, pet. denied) (mem. op.) ("[W]e may presume that a trial court took judicial notice of the file even if there is no record that the trial court did so expressly."). The record here indicates that Thoele subpoenaed three Board members and the Texas Department of Criminal Justice's (TDCJ) custodian of records to appear as witnesses at an April 2019 hearing on his motion for temporary injunction.

Further, with respect to the title documents, introduced by Appellee, the documents were copies certified by the Tarrant County Clerk. "[A] notarized, recorded, and certified deed meets the requirements of Texas Rule of Evidence 201 [permitting judicial notice of adjudicative facts], and . . . judicial notice is appropriate for such documents." Iqbal v. Fed. Nat'l Mortg. Ass'n, No. 03-15-00667-CV, 2017 WL 2856737, at *3 (Tex. App.—Austin June 29, 2017, pet. denied) (mem. op.) (collecting cases permitting judicial notice of title records). Below, the trial court did not explicitly state on the record that it was taking judicial notice of the exhibits from the temporary-injunction hearing, but the parties continuously referenced the exhibits.

Mother contends that the record is not clear whether the trial court actually took judicial notice because even though it inquired of the parties whether either had any objection to its taking judicial notice of its file, it never affirmatively stated on the record that it was so doing. However, the trial court was not required to affirmatively so state, as we may presume that it took judicial notice of the orders in its record of this case even without any request being made or any announcement in the record that it has been done. See In re A.J.W., No. 04-19-00346-CV, 2019 WL 6333468, at *3 (Tex. App.—San Antonio Nov. 27, 2019, no pet.) (mem. op.); Iqbal v. Federal Nat'l Mortg. Ass'n, No. 03-15-00667-CV, 2017 WL 2856737, at *3 (Tex. App.—Austin June 29, 2017, pet. denied) (mem. op.).

To prevail in a forcible detainer action when the property was purchased at a foreclosure sale, the plaintiff must prove that: (1) the substitute trustee conveyed the property by deed to the plaintiff after the foreclosure sale; (2) a landlord-tenant relationship existed and the occupants became tenants at sufferance; (3) the plaintiff gave proper notice to the occupants that it required them to vacate the premises; and (4) the occupants refused to vacate the premises. See TEX. PROP. CODE ANN. §§ 24.002, .005 (West 2014 & Supp. 2017); Murphy v. Countrywide Home Loans, Inc., 199 S.W.3d 441, 446-47 (Tex. App.—Houston [1st Dist.] 2006, pet. denied); see Iqbal v. Fed. Nat'l Mortg. Ass'n, No. 03-15-00667-CV, 2017 WL 2856737, at *2 (Tex. App.—Austin June 29, 2017, pet. denied) (mem. op.). Thus, forcible detainer actions cannot resolve any questions of title beyond the immediate right to possession.

In order to prevail in a forcible detainer action where the property was purchased at a foreclosure sale, the plaintiff must prove that: (1) the substitute trustee conveyed the property by deed to the plaintiff after the foreclosure sale; (2) a landlord-tenant relationship existed and the occupants became tenants at sufferance; (3) the plaintiff gave proper notice to the occupants that it required them to vacate the premises; and (4) the occupants refused to vacate the premises. See TEX. PROP. CODE ANN. §§ 24.002, .005 (West 2014 & Supp. 2017); Iqbal v. Fed. Nat'l Mortg. Ass'n , No. 03-15-00667-CV, 2017 WL 2856737, at *2 (Tex. App.—Austin June 29, 2017, pet. denied) (mem. op.); Murphy v. Countrywide Home Loans, Inc. , 199 S.W.3d 441, 445 (Tex. App.—Houston [1st Dist.] 2006, pet. denied). Thus, forcible detainer actions cannot resolve any questions of title beyond the immediate right to possession.

Moreover, to the extent that some details of her testimony would not tend to support the trial court's finding, we note that it was the court's role as fact-finder to weigh all the evidence and resolve apparent inconsistencies. See Iqbal v. Federal Nat'l Mortg. Ass'n, No. 03-15-00667-CV, 2017 WL 2856737, at *2 (Tex. App.—Austin June 29, 2017, no pet.) (mem. op.); Winkley v. State, 123 S.W.3d 707, 711 (Tex. App.—Austin 2003, no pet.). Having reviewed the evidence that the trial court describes in its order in light of the entire record before us, we cannot conclude that the court's finding that N.P. "cannot be rehabilitated in the juvenile system" was so against the great weight and preponderance of the proof as to be clearly wrong and unjust.