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FILED
TARRANT COUNTY
342-338616-22 11/22/2022 9:36 AM
THOMAS A. WILDER
CAUSE NO. ____________ DISTRICT CLERK
AEGIS SECURITY INSURANCE § IN THE DISTRICT COURT OF
COMPANY §
§
§
v. § TARRANT COUNTY, TEXAS
§
CUETO CONSULTING & CONSTRUCTION, §
ANDREW J. CUETO, AND §
ALISA ARY-CUETO §
§ ______ JUDICIAL DISTRICT
PETITION TO ENFORCE FOREIGN JUDGMENT PURSUANT TO
UNIFORM ENFORCEMENT OF FOREIGN JUDGMENTS ACT
Plaintiff Aegis Security Insurance Company files this Petition to Enforce Foreign
Judgment and the attached foreign judgment and affidavit pursuant to the Uniform Enforcement
of Foreign Judgments Act, Chapter 35 of the Texas Civil Practice & Remedies Code, and would
respectfully show unto the Court as follows:
PARTIES
1. Plaintiff, Aegis Security Insurance Company is a Pennsylvania corporation with its
principal place of business in Harrisburg, Pennsylvania.
2. Defendant Cueto Consulting & Construction LLC is a Texas limited liability
company that will be provided with a copy of this Petition to Enforce Foreign Judgment and the
Notice of Filing of Foreign Judgment by mailing a copy to its last known address at 900 Larkspur
Lane, Fort Worth, Texas 76112.
3. Defendant Andrew J. Cueto is an individual residing in Texas who will be provided
with a copy of this Petition to Enforce Foreign Judgment and the Notice of Filing of Foreign
Judgment by mailing a copy to his last known address at 900 Larkspur Lane, Fort Worth, Texas
76112.
4. Defendant Alisa Ary-Cueto is an individual residing in Texas, who will be provided
with a copy of this Petition to Enforce Foreign Judgment and the Notice of Filing of Foreign
Judgment by mailing a copy to her last known address at 900 Larkspur Lane, Fort Worth, Texas
76112.
ENFORCEMENT OF FOREIGN JUDGMENT
5. On September 26, 2022, a judgment was entered in favor of Aegis and against
Defendants by the Court of Common Pleas of Dauphin County, Pennsylvania under Case No.
2022-CV-07377-NT. An authenticated or certified copy of the judgment is attached to this Petition.
See Ex. A-1. This Petition is supported by the affidavit of Kim Moore on behalf of judgment
creditor Aegis Security Insurance Company. See Ex. A.
6. Defendants have failed to remit payment in full satisfaction of the Judgment, and
Plaintiff hereby seeks enforcement of the Judgment.
7. Plaintiff hereby prays that this Judgment of the Court of Common Pleas of Dauphin
County, Pennsylvania be accorded full faith and credit and have the same effect as a judgment of
this Court.
Respectfully submitted,
IRELAN MCDANIEL PLLC
By: /s/ Jacob M. Stephens
Jacob M. Stephens
State Bar No. 24066143
jstephens@imtexaslaw.com
2520 Caroline St., 2nd Floor
Houston, Texas 77004
(713) 222-7666 – Phone
(713) 222-7669 – Facsimile
Dean J. Siotos
State Bar No. 00793018
dsiotos@imtexaslaw.com
10440 North Central Expwy, Ste 800
Dallas, Texas 75231
Telephone: (214) 237-2996
Facsimile: (214) 237-2997
ATTORNEYS FOR PLAINTIFF
CERTIFICATE OF SERVICE AND PROOF OF MAILING
I hereby certify that on November 22, 2022, a true and correct copy of the foregoing
Petition to Enforce Foreign Judgment Pursuant to Uniform Enforcement of Foreign Judgments
Act was mailed by certified mail, return receipt requested, and by regular first-class mail, to
Defendants at the addresses shown in the notice, properly addressed as follows:
Cueto Consulting & Construction, LLC.
900 Larkspur Lane
Fort Worth, Texas 76112
Via CM-RRR No. 9414 7266 9904 2181 3354 88
And First-Class U.S. Mail
Andrew J. Cueto
900 Larkspur Lane
Fort Worth, Texas 76112
Via CM-RRR No. 9414 7266 9904 2181 3354 95
And First-Class U.S. Mail
Alisa Ary-Cueto
900 Larkspur Lane
Fort Worth, Texas 76112
Via CM-RRR No. 9414 7266 9904 2181 3355 01
And First-Class U.S. Mail
__/s/ Jacob M. Stephens____________
Jacob M. Stephens
EXHIBIT A
CAUSE NO. ____________
AEGIS SECURITY INSURANCE § IN THE DISTRICT COURT OF
COMPANY §
§
§
v. § TARRANT COUNTY, TEXAS
§
CUETO CONSULTING & CONSTRUCTION, §
ANDREW J. CUETO, AND §
ALISA ARY-CUETO §
§ ______ JUDICIAL DISTRICT
AFFIDAVIT IN SUPPORT OF FILING OF FOREIGN JUDGMENT
PURSUANT TO UNIFORM ENFORCEMENT OF FOREIGN JUDGMENTS ACT
STATE OF VIRGINIA §
COUNTY OF LOUDOUN §
BEFORE ME, the undersigned authority, on this day personally appeared Kim Moore,
personally known by me to be the person whose name is subscribed below and who, upon her oath,
stated as follows:
1. My name is Kim Moore. I am over 21 years of age, of sound mind, and capable of
making this affidavit. The facts stated in this affidavit are within my personal knowledge and are
true and correct.
2. I am a Senior Surety Consultant for On Point Risk Solutions, Inc. and am an
authorized representative of Aegis Security Insurance Company, the judgment creditor in this
matter holding Judgment dated September 26, 2022, which was certified on or about October 14,
2022, by the Prothonotary of the Court of Common Pleas of Dauphin County, Pennsylvania in
Case No. 2022-CV-07377-NT (collectively, the “Judgment”). A properly authenticated copy of
the Judgment is attached to this Affidavit and shall be filed with the Clerk of the above-captioned
Court.
3. The address for the judgment creditor is:
Aegis Security Insurance Company
4507 North Front Street, Suite 200
Harrisburg, PA 17110
EXHIBIT A-1
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Donna Hall on behalf of Jacob Stephens
Bar No. 24066143
dhall@IMTexasLaw.com
Envelope ID: 70390537
Status as of 11/22/2022 9:50 AM CST
Associated Case Party: Aegis Security Insurance Company
Name BarNumber Email TimestampSubmitted Status
Jacob MStephens jstephens@imtexaslaw.com 11/22/2022 9:36:39 AM SENT
Donna Hall dhall@imtexaslaw.com 11/22/2022 9:36:39 AM SENT
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FILED TARRANT COUNTY 342-338616-22 11/22/2022 9:36 AM THOMAS A. WILDER CAUSE NO. ____________ DISTRICT CLERK AEGIS SECURITY INSURANCE § IN THE DISTRICT COURT OF COMPANY § § § v. § TARRANT COUNTY, TEXAS § CUETO CONSULTING & CONSTRUCTION, § ANDREW J. CUETO, AND § ALISA ARY-CUETO § § ______ JUDICIAL DISTRICT PETITION TO ENFORCE FOREIGN JUDGMENT PURSUANT TO UNIFORM ENFORCEMENT OF FOREIGN JUDGMENTS ACT Plaintiff Aegis Security Insurance Company files this Petition to Enforce Foreign Judgment and the attached foreign judgment and affidavit pursuant to the Uniform Enforcement of Foreign Judgments Act, Chapter 35 of the Texas Civil Practice & Remedies Code, and would respectfully show unto the Court as follows: PARTIES 1. Plaintiff, Aegis Security Insurance Company is a Pennsylvania corporation with its principal place of business in Harrisburg, Pennsylvania. 2. Defendant Cueto Consulting & Construction LLC is a Texas limited liability company that will be provided with a copy of this Petition to Enforce Foreign Judgment and the Notice of Filing of Foreign Judgment by mailing a copy to its last known address at 900 Larkspur Lane, Fort Worth, Texas 76112. 3. Defendant Andrew J. Cueto is an individual residing in Texas who will be provided with a copy of this Petition to Enforce Foreign Judgment and the Notice of Filing of Foreign Judgment by mailing a copy to his last known address at 900 Larkspur Lane, Fort Worth, Texas 76112. 4. Defendant Alisa Ary-Cueto is an individual residing in Texas, who will be provided with a copy of this Petition to Enforce Foreign Judgment and the Notice of Filing of Foreign Judgment by mailing a copy to her last known address at 900 Larkspur Lane, Fort Worth, Texas 76112. ENFORCEMENT OF FOREIGN JUDGMENT 5. On September 26, 2022, a judgment was entered in favor of Aegis and against Defendants by the Court of Common Pleas of Dauphin County, Pennsylvania under Case No. 2022-CV-07377-NT. An authenticated or certified copy of the judgment is attached to this Petition. See Ex. A-1. This Petition is supported by the affidavit of Kim Moore on behalf of judgment creditor Aegis Security Insurance Company. See Ex. A. 6. Defendants have failed to remit payment in full satisfaction of the Judgment, and Plaintiff hereby seeks enforcement of the Judgment. 7. Plaintiff hereby prays that this Judgment of the Court of Common Pleas of Dauphin County, Pennsylvania be accorded full faith and credit and have the same effect as a judgment of this Court. Respectfully submitted, IRELAN MCDANIEL PLLC By: /s/ Jacob M. Stephens Jacob M. Stephens State Bar No. 24066143 jstephens@imtexaslaw.com 2520 Caroline St., 2nd Floor Houston, Texas 77004 (713) 222-7666 – Phone (713) 222-7669 – Facsimile Dean J. Siotos State Bar No. 00793018 dsiotos@imtexaslaw.com 10440 North Central Expwy, Ste 800 Dallas, Texas 75231 Telephone: (214) 237-2996 Facsimile: (214) 237-2997 ATTORNEYS FOR PLAINTIFF CERTIFICATE OF SERVICE AND PROOF OF MAILING I hereby certify that on November 22, 2022, a true and correct copy of the foregoing Petition to Enforce Foreign Judgment Pursuant to Uniform Enforcement of Foreign Judgments Act was mailed by certified mail, return receipt requested, and by regular first-class mail, to Defendants at the addresses shown in the notice, properly addressed as follows: Cueto Consulting & Construction, LLC. 900 Larkspur Lane Fort Worth, Texas 76112 Via CM-RRR No. 9414 7266 9904 2181 3354 88 And First-Class U.S. Mail Andrew J. Cueto 900 Larkspur Lane Fort Worth, Texas 76112 Via CM-RRR No. 9414 7266 9904 2181 3354 95 And First-Class U.S. Mail Alisa Ary-Cueto 900 Larkspur Lane Fort Worth, Texas 76112 Via CM-RRR No. 9414 7266 9904 2181 3355 01 And First-Class U.S. Mail __/s/ Jacob M. Stephens____________ Jacob M. Stephens EXHIBIT A CAUSE NO. ____________ AEGIS SECURITY INSURANCE § IN THE DISTRICT COURT OF COMPANY § § § v. § TARRANT COUNTY, TEXAS § CUETO CONSULTING & CONSTRUCTION, § ANDREW J. CUETO, AND § ALISA ARY-CUETO § § ______ JUDICIAL DISTRICT AFFIDAVIT IN SUPPORT OF FILING OF FOREIGN JUDGMENT PURSUANT TO UNIFORM ENFORCEMENT OF FOREIGN JUDGMENTS ACT STATE OF VIRGINIA § COUNTY OF LOUDOUN § BEFORE ME, the undersigned authority, on this day personally appeared Kim Moore, personally known by me to be the person whose name is subscribed below and who, upon her oath, stated as follows: 1. My name is Kim Moore. I am over 21 years of age, of sound mind, and capable of making this affidavit. The facts stated in this affidavit are within my personal knowledge and are true and correct. 2. I am a Senior Surety Consultant for On Point Risk Solutions, Inc. and am an authorized representative of Aegis Security Insurance Company, the judgment creditor in this matter holding Judgment dated September 26, 2022, which was certified on or about October 14, 2022, by the Prothonotary of the Court of Common Pleas of Dauphin County, Pennsylvania in Case No. 2022-CV-07377-NT (collectively, the “Judgment”). A properly authenticated copy of the Judgment is attached to this Affidavit and shall be filed with the Clerk of the above-captioned Court. 3. The address for the judgment creditor is: Aegis Security Insurance Company 4507 North Front Street, Suite 200 Harrisburg, PA 17110 EXHIBIT A-1 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Donna Hall on behalf of Jacob Stephens Bar No. 24066143 dhall@IMTexasLaw.com Envelope ID: 70390537 Status as of 11/22/2022 9:50 AM CST Associated Case Party: Aegis Security Insurance Company Name BarNumber Email TimestampSubmitted Status Jacob MStephens jstephens@imtexaslaw.com 11/22/2022 9:36:39 AM SENT Donna Hall dhall@imtexaslaw.com 11/22/2022 9:36:39 AM SENT