On December 29, 2010 a
Order
was filed
involving a dispute between
Rathburn, Lou,
and
Professional Bank Na,
The Systems Group Inc.,
Veritex Community Bank,
for GARNISHMENT
in the District Court of Dallas County.
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42.()6000294
Cause No. DC-10-16694
LOU RATHBURN, IN THE DISTRICT COURT
Plaintiff
Vs DALLAS COUNTY, TEXAS
SAFEGUARD SECURITY
HOLDINGS, et. al.
ee ee ee RR OE
RULE 11 AGREEMENT
TO THE HONORABLE JUDGE OF SAID COURT
COME NOW PLAINTIFF, LOU RATHBURN, and Defendants, J. MICHAEL LEGOW
and SAFEGUARD SECURITY HOLDINGS, INC, and SYSTEMS GROUP, INC., and
file this Rule 11 Agreement, made with respect to the final settlement of this case.
The parties agree as follows:
1. Plaintiff is entitled to recover from Defendants, jointly and severally, the
principal sum sued upon, plus attorney fees of $4,000 and costs of court.
2. Defendants shall remit to Plaintiff on February 22, 2011, through Plaintiff's
counsel, the sum of $10,000.
3. Defendants shall remit to Plaintiff, through Plaintiffs counsel, the sum of
$20,000, by March 31, 2011.
4. The balance of the amounts due will be paid no later than the 30" day of
June, 2011, through Plaintiffs counsel.
5. Upon receipt of the final payment, Plaintiff will file a nonsuit with prejudice.
6. In the event of default by Defendants of any payment, Plaintiff may present to
the Court an agreed judgment for immediate entry for the balance due and
owing.
7. Time is of the essence.
8. The Writ of Garnishment issued by this Court shall be immediately released.
9. The Application for Writ of Garnishment pending before the Court shall be
nonsuited effective with the filing of this Rule 11 Agreement.
Respectfully submitted,
LAW OFFICES OF KENNETH S. HARTER ALMON LAW FIRMfohnnic Almon
State Bar ID 091553 State Bar ID 24043533
1620 E. Beltline Rd. P. O. Box 786
Carrollton, Tx. 75006 Keller, Tx. 76244
(972) 242-8887 (817) 707-9464
FAX (972) 446-7976 FAX (817) 887-1435
ORDER
It appearing to the Court that the foregoing Rule 11 Agreement is appropriate, the
Court hereby approves same.
IT IS ORDERED That the Writ of Garnishment, previously issued by this Court is
hereby released and vacated.
Signed on this the 21" day of February, 201 t.
‘Judge Pres
ng
Document Filed Date
February 21, 2011
Case Filing Date
December 29, 2010
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42.()6000294 Cause No. DC-10-16694 LOU RATHBURN, IN THE DISTRICT COURT Plaintiff Vs DALLAS COUNTY, TEXAS SAFEGUARD SECURITY HOLDINGS, et. al. ee ee ee RR OE RULE 11 AGREEMENT TO THE HONORABLE JUDGE OF SAID COURT COME NOW PLAINTIFF, LOU RATHBURN, and Defendants, J. MICHAEL LEGOW and SAFEGUARD SECURITY HOLDINGS, INC, and SYSTEMS GROUP, INC., and file this Rule 11 Agreement, made with respect to the final settlement of this case. The parties agree as follows: 1. Plaintiff is entitled to recover from Defendants, jointly and severally, the principal sum sued upon, plus attorney fees of $4,000 and costs of court. 2. Defendants shall remit to Plaintiff on February 22, 2011, through Plaintiff's counsel, the sum of $10,000. 3. Defendants shall remit to Plaintiff, through Plaintiffs counsel, the sum of $20,000, by March 31, 2011. 4. The balance of the amounts due will be paid no later than the 30" day of June, 2011, through Plaintiffs counsel. 5. Upon receipt of the final payment, Plaintiff will file a nonsuit with prejudice. 6. In the event of default by Defendants of any payment, Plaintiff may present to the Court an agreed judgment for immediate entry for the balance due and owing. 7. Time is of the essence. 8. The Writ of Garnishment issued by this Court shall be immediately released. 9. The Application for Writ of Garnishment pending before the Court shall be nonsuited effective with the filing of this Rule 11 Agreement. Respectfully submitted, LAW OFFICES OF KENNETH S. HARTER ALMON LAW FIRMfohnnic Almon State Bar ID 091553 State Bar ID 24043533 1620 E. Beltline Rd. P. O. Box 786 Carrollton, Tx. 75006 Keller, Tx. 76244 (972) 242-8887 (817) 707-9464 FAX (972) 446-7976 FAX (817) 887-1435 ORDER It appearing to the Court that the foregoing Rule 11 Agreement is appropriate, the Court hereby approves same. IT IS ORDERED That the Writ of Garnishment, previously issued by this Court is hereby released and vacated. Signed on this the 21" day of February, 201 t. ‘Judge Pres ng