Preview
02/22/2008 10:42 9728999635 BROWN LAW OFFICE PAGE 02/09
CAUSE NO. 352-214202-05
RAYMOND SPOTH, GEORGE RAY, § IN THE DISTRICT COURT
INC., PSI PARTNERS, LTD., and PSI GP, §
LLC as the General Partner of PSI Partners § oc:
Ltd., §
§
Plaintiffs,
§ --,
~~-
-!r
§ ofTl
v. § oO
§ c:
fr""
~~c·-
PAUL PEEBLES, and FIRST OLD §
CAPITAL, INC., §
§
Defenda.nts. § 352nd JUDICIAL DISTRICT
DEFENDANTS' AMENDED MOTION FOR ENTRY OF FINAL JUDGMENT
Paul Peebles and First Old Capital, Inc. ("Defendants") filethis Amended Motion for
Entry of Final Judgment and would show the court the following:
1. Defendants have previously filed with this Court the following:
a. Defendants' Motion for Dismissal or Alternatively, Motion for Judgment
on the Verdict in Part and for Judgment Notwithstanding the Verdict in
Part;
b. Defendants' Response to Plaintiffs' Motion for Entry of Judgment on
Partial Jury Verdict and to Disregard Jury Findings and Supplement to
Motion for Judgment on the Verdict in Part and for Judgment
Notwithstanding the Verdict in Part; and,
c. Defendants' Motion for Entry afFinal Judgment.
2. Defendants submit the attached Final Judgment in lieu of the previously submitted
Final Judgment. The attached Final Judgment reflects findings as addressed in all pleadings
previously filed by Defendants, which are referenced above in Paragraphs la, 1b and k
DEFENDANTS' AMENDED MOTION FOR ENTRY OF FINAL JUDGMENT Pag< I
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Prayer
WHEREFORE, Defendants pray that this Court enter the proposed Fit1al Judgment
attached hereto.
Respectfully submitted,
Brown Law Office
1021 Long Prairie Road, Suite 402
Flower Mound, Texas 75028
Telephone: (972) 355-0092
Facsimile: (972) 899·9635
ATTORNEY FOR DEFENDANTS
CERTIFICATE OF SERVICE
I certify that on February 22, 2008, a true copy of the forgoing was served via facsimile and
regular mail on the following coun.sel of record:
William Frank Carroll
Cox Smith Matthews Incorporated
1201 Elm Street, Suite 3300
Dallas, Texas 75270
n .. .,,.,.,,., • NT~• • urmun
MnTTQN FOR ENTRY OF FINAL JUDGMENT
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A hearing on the above and foregoing Defendants' Motion for Entry of Final Judgment
has been set for the ___ day of _ _ _ _ _ _ _ __, 2008, at _ _ o'clock _ _m., in
the 352"d Judicial District Court of Tarrant County, Texas.
SIGNED on this _ _ day of _ _ _ _ __, 2008.
JUDGE PRESIDING
DEFENDANTS' AMENDED MOTION FOil. ENTIIY 011 FINi\L JUI)GllfENT PRg< j
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02/22/2008 10:42 9728999535 BROWN LAW OFFICE PAGE 05/09
CAUSE NO. 352~214202-05
RAYMOND SPOTH, GEORGE RAY, § IN THE DISTRICT COURT
INC., PSI PARTNERS, LTD., and PSI GP, §
LLC as the General Partner of PSI Partners §
Ltd., §
Plaintiffs, §
§
§ OF TARRANT COUNTY, TEXAS
v. §
§
PAUL PEEBLES, and FIRST OLD §
CAPITAL, INC., §
§
Defendants. § 352"d JUDICIAL DISTRICT
FINAL JUDGMENT
On September 18, 2006, the court called this case for trial. Plaintiff, Raymond Spoth,
("Spoth") appeared in person and through his attorney and announced ready for trial.Plaintiffs
George Ray, Inc., PSI Partners, Ltd., and PSI GP, L.L.C., as the General Partner of PSI Partners
Ltd. appeared through their representative and through their attorney and announced ready for
trial. Defendant, Paul Peebles "(Peebles"), appeared in person and through his attorney and
announced ready for tri.al. Defendant, First Old Capital, Inc. appeared through its represe.ntative
and through its attorney and announced ready for trial. The court impaneled and swore the jury,
which heard the evidence and arguments of counsel. The court submitted questions, definitions,
and instructions to the jury. In response, the jury made findings that the court received, filed, and
entered of record. The charge of the court and the verdict of the jury are incorporated for all
purposes by refere.nce. Defendants, Paul Peebles and First Old Capital, Inc., moved for judgment
on the verdict in part, and for judgment notwithstanding the verdict in part. The court considered
these motions, makes the following findings and renders judgment as follows for Defendants.
FINAl, .JUDGMENT Pogel
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IT IS ORDERED, ADJUDGED AND DECREED that, in accordance with 37.001, et
seq. of the Texas Civil Practice & Remedies Code, First Old Capital, Inc. is the owner of the
domain www.ocrl.com and the website content located at such address aud any and all necessary
coding to operate the website.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that Spath shall, within
ten days of the date of this judgment, notify, in writing, Network Solutions, Inc. that the domain
www.ocrl.com belongs to First Old Capital, Inc. and to request that Network Solutions, Inc.
release the lock on the domain www.ocrl.co:ro..
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that, accordance with
37.001, et seq. of the Texas Civil Practice & Remedies Code, First Old Capital, Inc. is the owner
of the trademarks/trade names "Old Capital," "Old Capital Residential Lending," and "First Old
Capital and Spath and George Ray, Inc. are ORDERED to take such actions as necessary within
ten days of the date of this judgment to withdraw the following trademark applications and/or
registrations previously submitted to and/or granted by the U.S. Trademark office:
OLD CAPITAL RESIDENTIAL LENDING w/design.
SERIAL NO: 76653135
OLD CAPITAL
SERIAL NO: 76648395
OLD CAPITAL RESIDENTIAL LENDING
SERIAL NO: 78716423
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that First Old Capital is
entitled to a permanent injunction enjoining and restraining Spoth and George Ray, Inc., and their
agents, employees and persons acting in concert or participation with either of them, from using the
names "Old Capital", "First Old Capital", "Old Capital Residential Lending", and "Old Capital
FJNAJ, .JUDGMENT Page~
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Residential Lending and Commercial Services." It is therefore, ORDERED that Spoth and George
Ray, Inc., and their agents, employees and persons acting in concert or participation vvith either of
them, are permanently enjoined and restrained from using the names "Old Capital", "First Old
Capital", "Old Capital Residential Lending'', and "Old Capital Residential Lending and
Commercial Services."
The court further finds that the viability of PSI Partners, Ltd. ("PSI") as an on-going business
venture is no longer possible and PSI and PSI GP, L.L.C., as the General Partner of PSI, should be
dissolved. TI1erefore, IT IS FURTHER ORDERED, ADJUDGED AND DECREED that PSI and
PSI GP, L.L.C. are hereby dissolved and the assets of PSI shall be sold and the proceeds of the
sale shall be divided 50/50 between Spoth and Peebles after payment of all outstanding PSI
debts. The sale shall be administered by Spoth and shall be conducted within 60 days of the date
of this judgment. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that the assets
shall be sold at their highest market value and an accounting of the sale proceeds shall be
provided to Pebbles. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that prior to
any PSI debts being paid, an accounting of the debts shall be provided by Spoth to Peebles a.nd
Peebles shall have 14 days in which to object to payment of any of the debts.
IT IS FURTHER ORDERED, ADillDGED AND DECREED that the jury's findings on
Jury Questions Nos. 3A,3B, 3D, 4B, 5B, 6B, 6D, 6F,, 7, 7A, 8, 9, 10, 11, 12, 13, 14, 17, 18, 19, 22,
23, 24, 25, 28 and 33 are accepted and judgment is entered thereon.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that the jury's findings on
Jury Questions Nos. 3C and 6C should be disregarded as they are precluded by law.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that the jury's findings on
FINALJUllGMl;NT Plll;t3
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Jury Questions Nos. 1, 2, 3C, 4, 4A, SA, 6A, 6C, 6E, 15, 16, 20, 21, 26, 27, 29, 30, 31 and 32
should be disregarded because these findings are not supported by the evidence presented at trial.
IT IS FURTIIER ORDERED, ADJUDGED AND DECREED that that Plaintiffs
Raymond Spoth, George Ray, Inc., PSI Partners, Ltd., and PSI GP, L.L.C., as the General Partner of
PSI Partners Ltd. (collectively "Plaintiffs"), take nothing by their suit except as set forth above,
and that Peebles, recover from Spoth, the total sum of $68,822.85, together with prejudgment
interest from October 17, 2005 until the date of judgment, at the rate of 6.00 percent per annum.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that Peebles have and
recover judgment against defendants, Raymond Spoth and George Ray, Inc., jointly and
severally, for his reasonable and necessary attorney fees in this Court in the amount of
$90,000.00,
IT IS FURTHER ORDERED, ADJUDGED AND DECREED tlw.t if a review of this matter
is sought by Plaintiffs, Peebles shall have and recover judgment against Raymond Spoth and
George Ray, Inc., jointly and severally, for his attorneys' fees as follows: $18,000.00 for an
appeal to the Court of Appeals; $8,000.00 for making 1md responding to an application for
petition for review to the Supreme Court of Texas; and $20,000.00 if a petition for review is
granted or briefing on the merits is requested by the Supreme Court of Texas.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that Peebles recover from
Spoth all his costs of court and post-:iudgment interest on all such sums at the rate of 7.25 percent
per annum from the date of judgment until paid.
IT IS FURTHER ORDERED, ADJUDGED AND DECREED that Peebles shall have all
writs of execution and other process as necessary to enforce 1his judgment.
FINAL .ltJDCMENT Png• 4
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All other relief sought by any party not specifically found, granted or denied, is expressly
denied.
SIGNED this _ _ day of _ _ _ __, 2008.
Bonnie Sudderth, Judge Presiding
FINAL JUDGMENT
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02/22/2008 10:42 9728999535 BROWN LAW OFFICE PAGE 01/09
THOMAS A. WILDER ~ TARRANT COUNTY DISTRICT CLERK
FAX TRANSMITTAL FORM
Attorney: BETTY L, BROWN Bar ID # 03094150
Finn Name: BROWN LAW OFFICE Fax# 972 899 9635
Subscriber Number: _ _ _,.;:9;...:5::;.:0~0:::..0~9;:::.3.::::3_ _ _ _ Telephone # _ __,9~7=..2,;..35"""5:....::0~0~92.....__ _
Representing: _ _ _ Plaintiff/Petitioner __1L Defendant/Respondent ___ Other
Authorization: I authorize the filing ofthe below named document(s) and I further authorize my checking
account to be debited in accordance with my subscriber's a.greement.
Signature:
Total number of Pages (inoluding this fonn) q Case Number (ifnnt neweue) 352-214202-05
This document should be filed in:
X Civil (For Civil ot Criminal please send your fax to: 817-850-l!Jifn ,_
--
Criminal CJ
C: g
~
(J') ""'T'"t
-1 i"'"1
::::0: {,/c:.o
__ Family (For Family or Juvenile please send your fax to: 817~8Sif:~27) ~
Juvenile
t-n~,i~'
If you ever have a problem, please call Sue at 817-884-1345 or Willie at 817-212-700~ ~
F"""
__ New Case Filing ''
__ Motions and other pleadings WITH F E E S : - - - - - - - - - - - - - - - - - - - - -
v"' Motions and other pleadings WITHOUT FEES:
REQUEST FOR SERVICE DOCUMENTS (Do you want us to issue citations or other docutncnt•?)
Type or service document Name of person to be served Address Type of service (constable,
Private, certified mail, etc)
1of9 2122/200810:41:43AM Central standard T i m e r - - - - - - - - - - - - - - - - - - - - - - - - 1 1
Preview
02/22/2008 10:42 9728999635 BROWN LAW OFFICE PAGE 02/09 CAUSE NO. 352-214202-05 RAYMOND SPOTH, GEORGE RAY, § IN THE DISTRICT COURT INC., PSI PARTNERS, LTD., and PSI GP, § LLC as the General Partner of PSI Partners § oc: Ltd., § § Plaintiffs, § --, ~~- -!r § ofTl v. § oO § c: fr"" ~~c·- PAUL PEEBLES, and FIRST OLD § CAPITAL, INC., § § Defenda.nts. § 352nd JUDICIAL DISTRICT DEFENDANTS' AMENDED MOTION FOR ENTRY OF FINAL JUDGMENT Paul Peebles and First Old Capital, Inc. ("Defendants") filethis Amended Motion for Entry of Final Judgment and would show the court the following: 1. Defendants have previously filed with this Court the following: a. Defendants' Motion for Dismissal or Alternatively, Motion for Judgment on the Verdict in Part and for Judgment Notwithstanding the Verdict in Part; b. Defendants' Response to Plaintiffs' Motion for Entry of Judgment on Partial Jury Verdict and to Disregard Jury Findings and Supplement to Motion for Judgment on the Verdict in Part and for Judgment Notwithstanding the Verdict in Part; and, c. Defendants' Motion for Entry afFinal Judgment. 2. Defendants submit the attached Final Judgment in lieu of the previously submitted Final Judgment. The attached Final Judgment reflects findings as addressed in all pleadings previously filed by Defendants, which are referenced above in Paragraphs la, 1b and k DEFENDANTS' AMENDED MOTION FOR ENTRY OF FINAL JUDGMENT Pag< I 2of9 21221200810:41:43 AM !Central standard TimeJ ~2/22/2~08 1~:42 9728999635 BROWN LAW OFFICE PAGE ~3/~9 Prayer WHEREFORE, Defendants pray that this Court enter the proposed Fit1al Judgment attached hereto. Respectfully submitted, Brown Law Office 1021 Long Prairie Road, Suite 402 Flower Mound, Texas 75028 Telephone: (972) 355-0092 Facsimile: (972) 899·9635 ATTORNEY FOR DEFENDANTS CERTIFICATE OF SERVICE I certify that on February 22, 2008, a true copy of the forgoing was served via facsimile and regular mail on the following coun.sel of record: William Frank Carroll Cox Smith Matthews Incorporated 1201 Elm Street, Suite 3300 Dallas, Texas 75270 n .. .,,.,.,,., • NT~• • urmun MnTTQN FOR ENTRY OF FINAL JUDGMENT 3of9 21221200810:41:43 AM [Central standard Time] 02/22/2008 10:42 9728999635 BROWN LAW OFFICE PAGE 04/09 A hearing on the above and foregoing Defendants' Motion for Entry of Final Judgment has been set for the ___ day of _ _ _ _ _ _ _ __, 2008, at _ _ o'clock _ _m., in the 352"d Judicial District Court of Tarrant County, Texas. SIGNED on this _ _ day of _ _ _ _ __, 2008. JUDGE PRESIDING DEFENDANTS' AMENDED MOTION FOil. ENTIIY 011 FINi\L JUI)GllfENT PRg< j 4of9 2122/200810:41:43 AM [Central Standard Time] 02/22/2008 10:42 9728999535 BROWN LAW OFFICE PAGE 05/09 CAUSE NO. 352~214202-05 RAYMOND SPOTH, GEORGE RAY, § IN THE DISTRICT COURT INC., PSI PARTNERS, LTD., and PSI GP, § LLC as the General Partner of PSI Partners § Ltd., § Plaintiffs, § § § OF TARRANT COUNTY, TEXAS v. § § PAUL PEEBLES, and FIRST OLD § CAPITAL, INC., § § Defendants. § 352"d JUDICIAL DISTRICT FINAL JUDGMENT On September 18, 2006, the court called this case for trial. Plaintiff, Raymond Spoth, ("Spoth") appeared in person and through his attorney and announced ready for trial.Plaintiffs George Ray, Inc., PSI Partners, Ltd., and PSI GP, L.L.C., as the General Partner of PSI Partners Ltd. appeared through their representative and through their attorney and announced ready for trial. Defendant, Paul Peebles "(Peebles"), appeared in person and through his attorney and announced ready for tri.al. Defendant, First Old Capital, Inc. appeared through its represe.ntative and through its attorney and announced ready for trial. The court impaneled and swore the jury, which heard the evidence and arguments of counsel. The court submitted questions, definitions, and instructions to the jury. In response, the jury made findings that the court received, filed, and entered of record. The charge of the court and the verdict of the jury are incorporated for all purposes by refere.nce. Defendants, Paul Peebles and First Old Capital, Inc., moved for judgment on the verdict in part, and for judgment notwithstanding the verdict in part. The court considered these motions, makes the following findings and renders judgment as follows for Defendants. FINAl, .JUDGMENT Pogel 5of9 21221200810:41:43AM [Central standard Time] 02/22/2008 10:42 9728999535 BROWN LAW OFFICE PAGE 06/09 IT IS ORDERED, ADJUDGED AND DECREED that, in accordance with 37.001, et seq. of the Texas Civil Practice & Remedies Code, First Old Capital, Inc. is the owner of the domain www.ocrl.com and the website content located at such address aud any and all necessary coding to operate the website. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that Spath shall, within ten days of the date of this judgment, notify, in writing, Network Solutions, Inc. that the domain www.ocrl.com belongs to First Old Capital, Inc. and to request that Network Solutions, Inc. release the lock on the domain www.ocrl.co:ro.. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that, accordance with 37.001, et seq. of the Texas Civil Practice & Remedies Code, First Old Capital, Inc. is the owner of the trademarks/trade names "Old Capital," "Old Capital Residential Lending," and "First Old Capital and Spath and George Ray, Inc. are ORDERED to take such actions as necessary within ten days of the date of this judgment to withdraw the following trademark applications and/or registrations previously submitted to and/or granted by the U.S. Trademark office: OLD CAPITAL RESIDENTIAL LENDING w/design. SERIAL NO: 76653135 OLD CAPITAL SERIAL NO: 76648395 OLD CAPITAL RESIDENTIAL LENDING SERIAL NO: 78716423 IT IS FURTHER ORDERED, ADJUDGED AND DECREED that First Old Capital is entitled to a permanent injunction enjoining and restraining Spoth and George Ray, Inc., and their agents, employees and persons acting in concert or participation with either of them, from using the names "Old Capital", "First Old Capital", "Old Capital Residential Lending", and "Old Capital FJNAJ, .JUDGMENT Page~ 6of9 2122/200810:41:43 AM [Central Standard Time] 02/22/2008 10:42 9728999635 BROWN LAW OFFICE PAGE 07/09 Residential Lending and Commercial Services." It is therefore, ORDERED that Spoth and George Ray, Inc., and their agents, employees and persons acting in concert or participation vvith either of them, are permanently enjoined and restrained from using the names "Old Capital", "First Old Capital", "Old Capital Residential Lending'', and "Old Capital Residential Lending and Commercial Services." The court further finds that the viability of PSI Partners, Ltd. ("PSI") as an on-going business venture is no longer possible and PSI and PSI GP, L.L.C., as the General Partner of PSI, should be dissolved. TI1erefore, IT IS FURTHER ORDERED, ADJUDGED AND DECREED that PSI and PSI GP, L.L.C. are hereby dissolved and the assets of PSI shall be sold and the proceeds of the sale shall be divided 50/50 between Spoth and Peebles after payment of all outstanding PSI debts. The sale shall be administered by Spoth and shall be conducted within 60 days of the date of this judgment. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that the assets shall be sold at their highest market value and an accounting of the sale proceeds shall be provided to Pebbles. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that prior to any PSI debts being paid, an accounting of the debts shall be provided by Spoth to Peebles a.nd Peebles shall have 14 days in which to object to payment of any of the debts. IT IS FURTHER ORDERED, ADillDGED AND DECREED that the jury's findings on Jury Questions Nos. 3A,3B, 3D, 4B, 5B, 6B, 6D, 6F,, 7, 7A, 8, 9, 10, 11, 12, 13, 14, 17, 18, 19, 22, 23, 24, 25, 28 and 33 are accepted and judgment is entered thereon. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that the jury's findings on Jury Questions Nos. 3C and 6C should be disregarded as they are precluded by law. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that the jury's findings on FINALJUllGMl;NT Plll;t3 7of9 21221200810:41:43 AM [Central standard Time] ~2/22/20~8 1~:42 9728999635 BROWN LAW OFFICE PAGE 08/~9 Jury Questions Nos. 1, 2, 3C, 4, 4A, SA, 6A, 6C, 6E, 15, 16, 20, 21, 26, 27, 29, 30, 31 and 32 should be disregarded because these findings are not supported by the evidence presented at trial. IT IS FURTIIER ORDERED, ADJUDGED AND DECREED that that Plaintiffs Raymond Spoth, George Ray, Inc., PSI Partners, Ltd., and PSI GP, L.L.C., as the General Partner of PSI Partners Ltd. (collectively "Plaintiffs"), take nothing by their suit except as set forth above, and that Peebles, recover from Spoth, the total sum of $68,822.85, together with prejudgment interest from October 17, 2005 until the date of judgment, at the rate of 6.00 percent per annum. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that Peebles have and recover judgment against defendants, Raymond Spoth and George Ray, Inc., jointly and severally, for his reasonable and necessary attorney fees in this Court in the amount of $90,000.00, IT IS FURTHER ORDERED, ADJUDGED AND DECREED tlw.t if a review of this matter is sought by Plaintiffs, Peebles shall have and recover judgment against Raymond Spoth and George Ray, Inc., jointly and severally, for his attorneys' fees as follows: $18,000.00 for an appeal to the Court of Appeals; $8,000.00 for making 1md responding to an application for petition for review to the Supreme Court of Texas; and $20,000.00 if a petition for review is granted or briefing on the merits is requested by the Supreme Court of Texas. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that Peebles recover from Spoth all his costs of court and post-:iudgment interest on all such sums at the rate of 7.25 percent per annum from the date of judgment until paid. IT IS FURTHER ORDERED, ADJUDGED AND DECREED that Peebles shall have all writs of execution and other process as necessary to enforce 1his judgment. FINAL .ltJDCMENT Png• 4 8of 92/22/200810:41:43 AM [Central standard Time] 02/22/2008 10:42 9728999635 BROWN LAW OFFICE PAGE 09/09 All other relief sought by any party not specifically found, granted or denied, is expressly denied. SIGNED this _ _ day of _ _ _ __, 2008. Bonnie Sudderth, Judge Presiding FINAL JUDGMENT 9of9 21221200810:41:43 AM [Central standard Time] 02/22/2008 10:42 9728999535 BROWN LAW OFFICE PAGE 01/09 THOMAS A. WILDER ~ TARRANT COUNTY DISTRICT CLERK FAX TRANSMITTAL FORM Attorney: BETTY L, BROWN Bar ID # 03094150 Finn Name: BROWN LAW OFFICE Fax# 972 899 9635 Subscriber Number: _ _ _,.;:9;...:5::;.:0~0:::..0~9;:::.3.::::3_ _ _ _ Telephone # _ __,9~7=..2,;..35"""5:....::0~0~92.....__ _ Representing: _ _ _ Plaintiff/Petitioner __1L Defendant/Respondent ___ Other Authorization: I authorize the filing ofthe below named document(s) and I further authorize my checking account to be debited in accordance with my subscriber's a.greement. Signature: Total number of Pages (inoluding this fonn) q Case Number (ifnnt neweue) 352-214202-05 This document should be filed in: X Civil (For Civil ot Criminal please send your fax to: 817-850-l!Jifn ,_ -- Criminal CJ C: g ~ (J') ""'T'"t -1 i"'"1 ::::0: {,/c:.o __ Family (For Family or Juvenile please send your fax to: 817~8Sif:~27) ~ Juvenile t-n~,i~' If you ever have a problem, please call Sue at 817-884-1345 or Willie at 817-212-700~ ~ F""" __ New Case Filing '' __ Motions and other pleadings WITH F E E S : - - - - - - - - - - - - - - - - - - - - - v"' Motions and other pleadings WITHOUT FEES: REQUEST FOR SERVICE DOCUMENTS (Do you want us to issue citations or other docutncnt•?) Type or service document Name of person to be served Address Type of service (constable, Private, certified mail, etc) 1of9 2122/200810:41:43AM Central standard T i m e r - - - - - - - - - - - - - - - - - - - - - - - - 1 1