Preview
FILED
6/14/2023 11:52 AM
D. Blake Apffel
JUSTICE OF THE PEACE PCT 2
GALVESTON COUNTY, TX
JUSTICE COURT CIVIL CASE INFORMATION SHEET (4/13)
CAUSE NUMBER (FOR CLERK USE ONLY):
STYLED Conn Appliances, Inc. vs. IVY JORDAN
A civil case information sheet must be completed and submitted when an original petition is filed to initiate a new suit. The
information should be the best available at the time of filing. This sheet, required by Rule of Civil Procedure 502, is intended to
collect information that will be used for statistical purposes only. It neither replaces nor supplements the filings or service of
pleading or other documents as required by law or rule. The sheet does not constitute a discovery request, response, or
supplementation, and it is not admissible at trial.
1. Contact information for person completing case 2. Names of parties in case:
information sheet:
Name: Telephone: Plaintiff(s):
Lacie Elizabeth Friday 888-599-6333 Conn Appliances, Inc.
Matthew Clark
Johnson Mark LLC
Defendant(s):
Address: Fax: Ivy Jordan
PO Box 7811 877-288-5701
City/State/Zip: State Bar No: [Attach additional page as necessary to list all parties]
Sandy, Utah 84091 24080901
Email:
Texasattorneys@jmlaw.com
Signature:
/s/Lacie Elizabeth Friday
3. Indicate case type, or identify the most important issue in the case (select only 1):
Debt Claim: A debt claim case is a lawsuit brought to recover a Eviction: An eviction case is a lawsuit brought to
debt by an assignee of a claim, a debt collector or collection agency, recover possession of real property, often by a landlord
a financial institution, or a person or entity primarily engaged in the against a tenant. A claim for rent may be joined with an
business of lending money at interest. The claim can be for no more eviction case if the amount of rent due and unpaid is not
than $10,000, excluding statutory interest and court costs but more than $10,000, excluding statutory interest and court
including attorney fees, if any. costs but including attorney fees, if any.
Repair and Remedy: A repair and remedy case is a lawsuit filed Small Claims: A small claims case is a lawsuit brought
by a residential tenant under Chapter 92, Subchapter B of the Texas for the recovery of money damages, civil penalties,
Property Code to enforce the landlord’s duty to repair or remedy a personal property, or other relief allowed by law. The claim
condition materially affecting the physical health or safety of an can be for no more than $10,000, excluding statutory
ordinary tenant. The relief sought can be for no more than $10,000, interest and court costs but including attorney fees, if any.
excluding statutory interest and court costs but including attorney
fees, if any.
23-46986
Cause No:________________
CONN APPLIANCES, INC., IN THE JUSTICE OF THE PEACE
Plaintiff,
vs. PRECINCT 2 PLACE 1
IVY JORDAN ,
Defendant. GALVESTON COUNTY, TEXAS
PLAINTIFF'S ORIGINAL PETITION
TO THE HONORABLE JUDGE OF SAID COURT:
Parties
Plaintiff, Conn Appliances, Inc., brings this debt claim case, which is within the
jurisdictional limits of this Court, under Rules 500-507 and 508 of the Texas Rules of Civil
Procedure.
1. Plaintiff is an entity organized and existing under the laws of the United States of
America and authorized to bring this action in the State of Texas.
2. Defendant, IVY JORDAN resides at 901 FM 517 RD W APT 219 DICKINSON TX
77539, or wherever they may be found, which is also where service of process can be made upon
the Defendant.
Venue
3. Venue is proper in Galveston County, Texas under Section 15.002(a)(2) of the Texas
Civil Practice and Remedies Code because it is the county of residence for one or more of the
Defendant at the time the cause of action accrued.
Contract Claim
4. Plaintiff’s claim is for Breach of Contract. The claim arises from a contract entered into
by Ivy Jordan with CONN APPLIANCES, INC., Account No. XXXXX0670 (“the Account”).
Plaintiff is the holder and sole owner of said Account. Defendant opened the Account on and
subsequently breached the contract by failing to make all required payments under the
agreement. The Defendant owes $3,104.69 in damages. The Account was closed/charged-off on
11/30/2022. Plaintiff now sues herein for actual damages, cost of court, and continuing
post-judgment interest.
Debt Claim
5. In the alternative, Plaintiff’s claim is for Account Stated and/or Open Account. The claim
arises from a Credit Account entered into by Ivy Jordan with CONN APPLIANCES, INC.,
23-46986
Account No. XXXXX0670 (“the Account”). Plaintiff is the holder and sole owner of said
Account. Defendant opened the Account on . The Account is in default and Plaintiff sues herein
for actual damages, cost of court, and continuing post-judgment interest. The Defendant owes
$3,104.69 in damages. The Account was closed/charge-off on 11/30/2022.
Prayer
Plaintiff requests that the Defendant be cited to appear and answer herein, that this Court
set this matter for hearing. Upon final hearing, the Plaintiff seeks a judgment against the
Defendant for damages totaling $3,104.69, costs of court, as well as all other relief to which they
are entitled.
JOHNSON MARK LLC
By /s/Lacie Elizabeth Friday
Lacie Elizabeth Friday SBN 24080901
Sean Morrissey SBN 24127403
Matthew Clark SBN 24100155
Victoria Barboza SBN 24116069
Lauren Jones SBN 24120155
P.O. Box 7811 Sandy, Utah 84091-7811
Tel 888-599-6333
Texasattorneys@jmlaw.com
Attorneys for Plaintiff
23-46986
Cause No.
CONN APPLIANCES, INC., IN THE JUSTICE OF THE PEACE
Plaintiff,
vs. PRECINCT 2 PLACE 1
IVY JORDAN ,
Defendant. GALVESTON COUNTY, TEXAS
NON-MILITARY DECLARATION UNDER PENALTY OF PERJURY PURSUANT TO
TEX. CIV. PRAC. & REM. CODE § 132.001
Pursuant to Texas Civil Practice and Remedies Code §132.001, which provides that "an
unsworn declaration may be used in lieu of a written sworn declaration, verification,
certification, oath or affidavit required by statute or required by a rule, order, or requirement
adopted as provided by law," and Texas Business and Commerce Code §322.007 which provides
that "if a law requires a record to be in writing, an electronic record satisfies the law" and "if a
law requires a signature, an electronic signature satisfies the law," the undersigned attorney
hereby submits the following unsworn declaration under penalty of perjury as to the military
status of the Defendant Ivy Jordan:
1. I am employed as an attorney by the law firm of Johnson Mark, LLC, which is the law
firm representing Plaintiff in the above-styled cause. I am one of the attorneys responsible for
overseeing the litigation of this cause.
2. The Department of Defense Manpower Data Center indicates that the Defendant is not
currently on active duty, has not been on active duty in the past 367 days, or has not been
notified of a future call-up to active duty in any branch of the Armed Forces. A copy of the
results are attached.
3. Based upon my review of the matter, the attached results, and to the best of my
knowledge, the Defendant is not currently on active duty in any branch of the Armed Forces.
My name is Lacie Friday, my date of birth is XX/XX/1980, and my address is P.O. Box
7811 Sandy, Utah 84091, and United States of America. I declare under penalty of perjury that
the foregoing is true and correct.
Executed in Grayson County, State of Texas, on June 12, 2023.
JOHNSON MARK LLC
By /s/Lacie Elizabeth Friday
Lacie Elizabeth Friday SBN 24080901
Sean Morrissey SBN 24127403
Matthew Clark SBN 24100155
Victoria Barboza SBN 24116069
Lauren Jones SBN 24120155
P.O. Box 7811 Sandy, Utah 84091-7811
Tel 888-599-6333
Texasattorneys@jmlaw.com
Attorneys for Plaintiff
23-46986
700 Highlander Blvd #200, Arlington, TX 76015
In re: IVY JORDAN Phone: 214-920-9688
0108432-994
PARTNER
ABC E-File Texas
E-FILE ONLY, Dallas, TX 75220
Clerk of the Justice Court
Galveston County, Texas
11730 Highway 6 ORIGINAL PETITION – CIVIL CASE
Santa Fe, TX 77510 JUSTICE COURT
RE: Conn Appliances, Inc. vs. IVY JORDAN; TX Precinct 2 Justice Court for Galveston County
Dear Sir or Madam:
Enclosed please find the following documents:
• Cover letter
• Original Petition (Original plus copies)
Instructions:
• Please file the Original Petition
• Please issue a separate Citation for each defendant for service by a private process server
The Citation(s) should be issued to:
IVY JORDAN
901 FM 517 RD W APT 219
DICKINSON, TX 77539
• Please return this coversheet, the original Citation, and a filed-stamped copy of the Original
Petition to ABC Legal by:
X Mail to ABC Legal at 700 Highlander Blvd Ste 200, Arlington TX 76015
Hold for pickup by local ABC courier
Email to txefile@abclegal.com
Thank you in advance for your assistance!
ABC Legal Services
In re: IVY JORDAN
** Please do not throw me away **
Return this page with the citation and petition
0108432-994
This barcode is very important to us
Generated: 06/14/2023
Preview
FILED 6/14/2023 11:52 AM D. Blake Apffel JUSTICE OF THE PEACE PCT 2 GALVESTON COUNTY, TX JUSTICE COURT CIVIL CASE INFORMATION SHEET (4/13) CAUSE NUMBER (FOR CLERK USE ONLY): STYLED Conn Appliances, Inc. vs. IVY JORDAN A civil case information sheet must be completed and submitted when an original petition is filed to initiate a new suit. The information should be the best available at the time of filing. This sheet, required by Rule of Civil Procedure 502, is intended to collect information that will be used for statistical purposes only. It neither replaces nor supplements the filings or service of pleading or other documents as required by law or rule. The sheet does not constitute a discovery request, response, or supplementation, and it is not admissible at trial. 1. Contact information for person completing case 2. Names of parties in case: information sheet: Name: Telephone: Plaintiff(s): Lacie Elizabeth Friday 888-599-6333 Conn Appliances, Inc. Matthew Clark Johnson Mark LLC Defendant(s): Address: Fax: Ivy Jordan PO Box 7811 877-288-5701 City/State/Zip: State Bar No: [Attach additional page as necessary to list all parties] Sandy, Utah 84091 24080901 Email: Texasattorneys@jmlaw.com Signature: /s/Lacie Elizabeth Friday 3. Indicate case type, or identify the most important issue in the case (select only 1): Debt Claim: A debt claim case is a lawsuit brought to recover a Eviction: An eviction case is a lawsuit brought to debt by an assignee of a claim, a debt collector or collection agency, recover possession of real property, often by a landlord a financial institution, or a person or entity primarily engaged in the against a tenant. A claim for rent may be joined with an business of lending money at interest. The claim can be for no more eviction case if the amount of rent due and unpaid is not than $10,000, excluding statutory interest and court costs but more than $10,000, excluding statutory interest and court including attorney fees, if any. costs but including attorney fees, if any. Repair and Remedy: A repair and remedy case is a lawsuit filed Small Claims: A small claims case is a lawsuit brought by a residential tenant under Chapter 92, Subchapter B of the Texas for the recovery of money damages, civil penalties, Property Code to enforce the landlord’s duty to repair or remedy a personal property, or other relief allowed by law. The claim condition materially affecting the physical health or safety of an can be for no more than $10,000, excluding statutory ordinary tenant. The relief sought can be for no more than $10,000, interest and court costs but including attorney fees, if any. excluding statutory interest and court costs but including attorney fees, if any. 23-46986 Cause No:________________ CONN APPLIANCES, INC., IN THE JUSTICE OF THE PEACE Plaintiff, vs. PRECINCT 2 PLACE 1 IVY JORDAN , Defendant. GALVESTON COUNTY, TEXAS PLAINTIFF'S ORIGINAL PETITION TO THE HONORABLE JUDGE OF SAID COURT: Parties Plaintiff, Conn Appliances, Inc., brings this debt claim case, which is within the jurisdictional limits of this Court, under Rules 500-507 and 508 of the Texas Rules of Civil Procedure. 1. Plaintiff is an entity organized and existing under the laws of the United States of America and authorized to bring this action in the State of Texas. 2. Defendant, IVY JORDAN resides at 901 FM 517 RD W APT 219 DICKINSON TX 77539, or wherever they may be found, which is also where service of process can be made upon the Defendant. Venue 3. Venue is proper in Galveston County, Texas under Section 15.002(a)(2) of the Texas Civil Practice and Remedies Code because it is the county of residence for one or more of the Defendant at the time the cause of action accrued. Contract Claim 4. Plaintiff’s claim is for Breach of Contract. The claim arises from a contract entered into by Ivy Jordan with CONN APPLIANCES, INC., Account No. XXXXX0670 (“the Account”). Plaintiff is the holder and sole owner of said Account. Defendant opened the Account on and subsequently breached the contract by failing to make all required payments under the agreement. The Defendant owes $3,104.69 in damages. The Account was closed/charged-off on 11/30/2022. Plaintiff now sues herein for actual damages, cost of court, and continuing post-judgment interest. Debt Claim 5. In the alternative, Plaintiff’s claim is for Account Stated and/or Open Account. The claim arises from a Credit Account entered into by Ivy Jordan with CONN APPLIANCES, INC., 23-46986 Account No. XXXXX0670 (“the Account”). Plaintiff is the holder and sole owner of said Account. Defendant opened the Account on . The Account is in default and Plaintiff sues herein for actual damages, cost of court, and continuing post-judgment interest. The Defendant owes $3,104.69 in damages. The Account was closed/charge-off on 11/30/2022. Prayer Plaintiff requests that the Defendant be cited to appear and answer herein, that this Court set this matter for hearing. Upon final hearing, the Plaintiff seeks a judgment against the Defendant for damages totaling $3,104.69, costs of court, as well as all other relief to which they are entitled. JOHNSON MARK LLC By /s/Lacie Elizabeth Friday Lacie Elizabeth Friday SBN 24080901 Sean Morrissey SBN 24127403 Matthew Clark SBN 24100155 Victoria Barboza SBN 24116069 Lauren Jones SBN 24120155 P.O. Box 7811 Sandy, Utah 84091-7811 Tel 888-599-6333 Texasattorneys@jmlaw.com Attorneys for Plaintiff 23-46986 Cause No. CONN APPLIANCES, INC., IN THE JUSTICE OF THE PEACE Plaintiff, vs. PRECINCT 2 PLACE 1 IVY JORDAN , Defendant. GALVESTON COUNTY, TEXAS NON-MILITARY DECLARATION UNDER PENALTY OF PERJURY PURSUANT TO TEX. CIV. PRAC. & REM. CODE § 132.001 Pursuant to Texas Civil Practice and Remedies Code §132.001, which provides that "an unsworn declaration may be used in lieu of a written sworn declaration, verification, certification, oath or affidavit required by statute or required by a rule, order, or requirement adopted as provided by law," and Texas Business and Commerce Code §322.007 which provides that "if a law requires a record to be in writing, an electronic record satisfies the law" and "if a law requires a signature, an electronic signature satisfies the law," the undersigned attorney hereby submits the following unsworn declaration under penalty of perjury as to the military status of the Defendant Ivy Jordan: 1. I am employed as an attorney by the law firm of Johnson Mark, LLC, which is the law firm representing Plaintiff in the above-styled cause. I am one of the attorneys responsible for overseeing the litigation of this cause. 2. The Department of Defense Manpower Data Center indicates that the Defendant is not currently on active duty, has not been on active duty in the past 367 days, or has not been notified of a future call-up to active duty in any branch of the Armed Forces. A copy of the results are attached. 3. Based upon my review of the matter, the attached results, and to the best of my knowledge, the Defendant is not currently on active duty in any branch of the Armed Forces. My name is Lacie Friday, my date of birth is XX/XX/1980, and my address is P.O. Box 7811 Sandy, Utah 84091, and United States of America. I declare under penalty of perjury that the foregoing is true and correct. Executed in Grayson County, State of Texas, on June 12, 2023. JOHNSON MARK LLC By /s/Lacie Elizabeth Friday Lacie Elizabeth Friday SBN 24080901 Sean Morrissey SBN 24127403 Matthew Clark SBN 24100155 Victoria Barboza SBN 24116069 Lauren Jones SBN 24120155 P.O. Box 7811 Sandy, Utah 84091-7811 Tel 888-599-6333 Texasattorneys@jmlaw.com Attorneys for Plaintiff 23-46986 700 Highlander Blvd #200, Arlington, TX 76015 In re: IVY JORDAN Phone: 214-920-9688 0108432-994 PARTNER ABC E-File Texas E-FILE ONLY, Dallas, TX 75220 Clerk of the Justice Court Galveston County, Texas 11730 Highway 6 ORIGINAL PETITION – CIVIL CASE Santa Fe, TX 77510 JUSTICE COURT RE: Conn Appliances, Inc. vs. IVY JORDAN; TX Precinct 2 Justice Court for Galveston County Dear Sir or Madam: Enclosed please find the following documents: • Cover letter • Original Petition (Original plus copies) Instructions: • Please file the Original Petition • Please issue a separate Citation for each defendant for service by a private process server The Citation(s) should be issued to: IVY JORDAN 901 FM 517 RD W APT 219 DICKINSON, TX 77539 • Please return this coversheet, the original Citation, and a filed-stamped copy of the Original Petition to ABC Legal by: X Mail to ABC Legal at 700 Highlander Blvd Ste 200, Arlington TX 76015 Hold for pickup by local ABC courier Email to txefile@abclegal.com Thank you in advance for your assistance! ABC Legal Services In re: IVY JORDAN ** Please do not throw me away ** Return this page with the citation and petition 0108432-994 This barcode is very important to us Generated: 06/14/2023