On December 14, 2018 a
Judgment
was filed
involving a dispute between
and
for CONTRACT, FRAUD/MISREPRESENTATION
in the District Court of Tarrant County.
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236-304998-18
FILED
TARRANT COUNTY
2/20/2019 3:14 PM
THOMAS A. WILDER
DISTRICT CLERK
CAUSE NUMBER 236-304998-18
CHARLES DOUGLAS, on behalf of § IN THE DISTRICT COURT
TCU PEE WEE YOUTH §
ASSOCIATION, INC. §
Plaintiff, §
§
v. §
§
EARL STEWART, RAYFORD §
ROCHON, CEDRIC DORSEY SR., § 236TH JUDICIAL DISTRICT
ADRIAN DORSEY, d/b/a TCU PEE §
WEE YOUTH FOOTBALL §
ASSOCIATION, d/b/a §
TCU SPORTS ASSOCIATION, §
d/b/a TCU PEE WEE FOOTBALL §
ASSOCIATION, and NORTH §
TEXAS FOOTBALL YOUTH §
ASSOCIATION §
Defendants. § TARRANT COUNTY, TEXAS
MOTION FOR DEFAULT JUDGMENT
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Charles Douglas, on behalf of TCU Pee Wee Youth Association,
Inc., (hereinafter referred to as “Plaintiff”), and moves for a judgment against Adrian
Dorsey, (hereinafter referred to as “Dorsey”), because the Defendant, though duly
served with process, has failed to file a written verified answer, and wholly made
default in that return of service that has been on file in this Cause for at least ten
(10) days.
On December 12, 2018, Plaintiff filed his Verified Original Petition for
Injunctive Relief, Damages, and Temporary Restraining Order against Defendant in
Motion for Default Judgment Page 1 of 4
the 236th Judicial District Court of Tarrant County, Texas. On January 22, 2019,
Defendant was duly and properly served with Verified Original Petition for Injunctive
Relief, Damages, and Temporary Restraining Order. The deadline for Defendant to
file a written verified answer with this Court was on February 18, 2019. As of
February 20, 2019, Defendant has not filed a written verified answer with this Court,
and wholly made default.
A copy of the Citation with Officer’s Return is attached hereto and incorporated
herein as Exhibit “A”.
WHEREFORE, Plaintiff prays that this Court grant this Motion for Default
Judgment and enter a judgment against Defendant Adrian Dorsey.
Respectfully submitted,
Joshua Graham Trial Lawyers
Water Gardens Place
100 E 15th Street, Suite 635
Fort Worth, Texas 76102
T: 817-789-4000
F: 817-789-4001
Kursten King
State Bar No. 24097097
kbking@joshuagraham.com
Joshua Stewart Graham
State Bar No. 24080736
jsg@joshuagraham.com
Motion for Default Judgment Page 2 of 4
CERTIFICATE OF LAST KNOWN ADDRESS
I hereby certify that based on a review of Plaintiff’s records and records of
public domain, the last known address of Cedric Dorsey in the above-entitled cause,
is 4772 Grapevine Terr., Fort Worth, Texas 76123.
Kursten King
kbking@joshuagraham.com
Motion for Default Judgment Page 3 of 4
CERTIFICATE OF SERVICE
I hereby certify that on February 20, 2019, a true and correct copy of the
foregoing Motion for Default Judgment has been served upon Defendant in
accordance with the Texas Rules of Civil Procedure.
Kursten King
kbking@joshuagraham.com
Motion for Default Judgment Page 4 of 4
Document Filed Date
February 20, 2019
Case Filing Date
December 14, 2018
Category
CONTRACT, FRAUD/MISREPRESENTATION
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236-304998-18 FILED TARRANT COUNTY 2/20/2019 3:14 PM THOMAS A. WILDER DISTRICT CLERK CAUSE NUMBER 236-304998-18 CHARLES DOUGLAS, on behalf of § IN THE DISTRICT COURT TCU PEE WEE YOUTH § ASSOCIATION, INC. § Plaintiff, § § v. § § EARL STEWART, RAYFORD § ROCHON, CEDRIC DORSEY SR., § 236TH JUDICIAL DISTRICT ADRIAN DORSEY, d/b/a TCU PEE § WEE YOUTH FOOTBALL § ASSOCIATION, d/b/a § TCU SPORTS ASSOCIATION, § d/b/a TCU PEE WEE FOOTBALL § ASSOCIATION, and NORTH § TEXAS FOOTBALL YOUTH § ASSOCIATION § Defendants. § TARRANT COUNTY, TEXAS MOTION FOR DEFAULT JUDGMENT TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Charles Douglas, on behalf of TCU Pee Wee Youth Association, Inc., (hereinafter referred to as “Plaintiff”), and moves for a judgment against Adrian Dorsey, (hereinafter referred to as “Dorsey”), because the Defendant, though duly served with process, has failed to file a written verified answer, and wholly made default in that return of service that has been on file in this Cause for at least ten (10) days. On December 12, 2018, Plaintiff filed his Verified Original Petition for Injunctive Relief, Damages, and Temporary Restraining Order against Defendant in Motion for Default Judgment Page 1 of 4 the 236th Judicial District Court of Tarrant County, Texas. On January 22, 2019, Defendant was duly and properly served with Verified Original Petition for Injunctive Relief, Damages, and Temporary Restraining Order. The deadline for Defendant to file a written verified answer with this Court was on February 18, 2019. As of February 20, 2019, Defendant has not filed a written verified answer with this Court, and wholly made default. A copy of the Citation with Officer’s Return is attached hereto and incorporated herein as Exhibit “A”. WHEREFORE, Plaintiff prays that this Court grant this Motion for Default Judgment and enter a judgment against Defendant Adrian Dorsey. Respectfully submitted, Joshua Graham Trial Lawyers Water Gardens Place 100 E 15th Street, Suite 635 Fort Worth, Texas 76102 T: 817-789-4000 F: 817-789-4001 Kursten King State Bar No. 24097097 kbking@joshuagraham.com Joshua Stewart Graham State Bar No. 24080736 jsg@joshuagraham.com Motion for Default Judgment Page 2 of 4 CERTIFICATE OF LAST KNOWN ADDRESS I hereby certify that based on a review of Plaintiff’s records and records of public domain, the last known address of Cedric Dorsey in the above-entitled cause, is 4772 Grapevine Terr., Fort Worth, Texas 76123. Kursten King kbking@joshuagraham.com Motion for Default Judgment Page 3 of 4 CERTIFICATE OF SERVICE I hereby certify that on February 20, 2019, a true and correct copy of the foregoing Motion for Default Judgment has been served upon Defendant in accordance with the Texas Rules of Civil Procedure. Kursten King kbking@joshuagraham.com Motion for Default Judgment Page 4 of 4