On December 29, 2010 a
Complaint,Petition
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.
Preview
Cause No. DC-10- I )= lola fy lone,
eo
Erp, <9
LOU RATHBURN § IN THE DISTRICT @D Pea
§ Cy A
Plaintiff § Vag +
§
Vs § DALLAS COUNTY, TEXAS
§
SAFEGUARD SECURITY HOLDINGS = §
INC. & R. MICHAE!. LAGOW §
§
Defendants § 134t.G JUDICIAL DISTRICT COURT
Petition
1, Discovery in this action is intended to be conducted under Level | in accordance with the
Texas Rules of Civil Procedure, Rule 190.1.
2. Plaintiff is an individual residing in Mineola, Texas.
3, Defendant R. MICHAEL LAGOW is an individual residing in Dallas, Texas. He may be
served with process at 4801 Spring Valley Road, Dallas, Texas.
Defendant SAFEGUARD SECURITY HOLDINGS, INC., is a domestic corporation
qualified to do business and doing business in the state of Texas. It may be served with
process by serving its registered agent:
CT Corporation System
350 North St. Paul St.
Dallas, Tx.
4. On or about October 21, 2010, in Dallas County, Texas, defendant SAFEGUARD
SECURITY HOLDINGS, INC., for value received, executed and delivered to plaintiff a
promissory note in the sum of $69,181.32. Plaintiff is the owner and holder of the note.
Defendant has defaulted on his obligation to make payments on the note. Accordingly, the
entire balance of the note, $56,341.42, is now due and payable.
5. Defendant R. MICHAEL LAGOW signed an irrevocable and unconditional guarantee of
payment of the note. Accordingly, said defendant is fully liable for all amounts duc
thereunder.
6. By the terms of the said note, Plaintiff is also entitled to recover of Defendants
SAFEGUARD SECURITY HOLDINGS INC. and R. MICHAEL LAGOW the reasonable
_———..———eeee ——————————
Original Petition Page 1o
and necessary attorney fees incurred in the collection of this debt. Plaintiff has retained the
undersigned law firm to prosecute this case. Plaintiff prays that she recover judgment for the
reasonable and necessary attorney fees incurred in the trial and appeals of this case.
WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that Defendants be cited to
answer and appear herein, and that upon final trial Plaintiff be awarded judgment for the
principal amount duc, plus prejudgment interest, postjudgment interest, attorney fecs, costs
of suit, and such other and further relief as the court deems just.
Respectfully submitted,
W OFFICES OF KENNETH S .HARTER
State Bar ID 09155300
1620 E. Beltline Rd.
Carrollton, Tx. 75006
(972) 242-8887
FAX (972) 446-7976
Original Petition Page 2
Document Filed Date
December 29, 2010
Case Filing Date
December 29, 2010
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Cause No. DC-10- I )= lola fy lone, eo Erp, <9 LOU RATHBURN § IN THE DISTRICT @D Pea § Cy A Plaintiff § Vag + § Vs § DALLAS COUNTY, TEXAS § SAFEGUARD SECURITY HOLDINGS = § INC. & R. MICHAE!. LAGOW § § Defendants § 134t.G JUDICIAL DISTRICT COURT Petition 1, Discovery in this action is intended to be conducted under Level | in accordance with the Texas Rules of Civil Procedure, Rule 190.1. 2. Plaintiff is an individual residing in Mineola, Texas. 3, Defendant R. MICHAEL LAGOW is an individual residing in Dallas, Texas. He may be served with process at 4801 Spring Valley Road, Dallas, Texas. Defendant SAFEGUARD SECURITY HOLDINGS, INC., is a domestic corporation qualified to do business and doing business in the state of Texas. It may be served with process by serving its registered agent: CT Corporation System 350 North St. Paul St. Dallas, Tx. 4. On or about October 21, 2010, in Dallas County, Texas, defendant SAFEGUARD SECURITY HOLDINGS, INC., for value received, executed and delivered to plaintiff a promissory note in the sum of $69,181.32. Plaintiff is the owner and holder of the note. Defendant has defaulted on his obligation to make payments on the note. Accordingly, the entire balance of the note, $56,341.42, is now due and payable. 5. Defendant R. MICHAEL LAGOW signed an irrevocable and unconditional guarantee of payment of the note. Accordingly, said defendant is fully liable for all amounts duc thereunder. 6. By the terms of the said note, Plaintiff is also entitled to recover of Defendants SAFEGUARD SECURITY HOLDINGS INC. and R. MICHAEL LAGOW the reasonable _———..———eeee —————————— Original Petition Page 1o and necessary attorney fees incurred in the collection of this debt. Plaintiff has retained the undersigned law firm to prosecute this case. Plaintiff prays that she recover judgment for the reasonable and necessary attorney fees incurred in the trial and appeals of this case. WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that Defendants be cited to answer and appear herein, and that upon final trial Plaintiff be awarded judgment for the principal amount duc, plus prejudgment interest, postjudgment interest, attorney fecs, costs of suit, and such other and further relief as the court deems just. Respectfully submitted, W OFFICES OF KENNETH S .HARTER State Bar ID 09155300 1620 E. Beltline Rd. Carrollton, Tx. 75006 (972) 242-8887 FAX (972) 446-7976 Original Petition Page 2