Preview
Filed: 4/20/2021 8:49 AM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 52619460
By: Lisa Kelly
CASE NO.: 21-CV-0046 4/20/2021 9:00 AM
AMERICAN EXPRESS NATIONAL BANK, IN THE Galveston County 122nd District Court
Plaintiff(s),
vs. Galveston COUNTY, TX
URSULA REED a/k/a U. DARLA REED,
Defendant(s).
MOTION FOR RULE 106 SERVICE
Plaintiff moves the Court to order service of Citation; Plaintiff's Original Petition on
Defendant(s), URSULA REED a/k/a U. DARLA REED, by delivering to Defendant(s), URSULA REED
a/k/a U. DARLA REED, as prescribed by Rule 106 of the T.R.C.P.
Private Process Server, Ro n a l d Wa l te r Ki rk , licensed in the State of Texas with license number
PS C : 18 5 4 3 EX P : 08 / 3 1 / 2 0 2 2 , has made 4 unsuccessful attempts and other efforts to personally
serve Citation; Plaintiff's Original Petition to be served upon said Defendant(s) as indicated by
the attached affidavit.
Plaintiff requests the Court issue an order authorizing substituted service of Citation; Plaintiff's
Original Petition as prescribed by Rule 106 of the T.R.C.P., by delivering a true and correct copy
of the Citation; Plaintiff's Original Petition to anyone over the age of sixteen (16), or by affixing
to the front entrance at the Defendant(s)'s usual place of abode, 13885 RED OAK CIR S , Mc
K in n e y , T X 7 5 0 7 1 .
Respectfully Submitted:
/S/Donald D. DeGrasse
_________________________________
THE DEGRASSE LAW FIRM, PC
Donald DeGrasse
State Bar No. 05641800
Eric M. Spence
State Bar No. 24070658
Beatrice Grevel
State Bar No. 00796677
Leonidia Leo Vidal Glasper
State Bar No. 24111179
E-mail: attorneys@degrasselaw.com
1800 Bering Drive, Suite 1000
Houston, TX 77057
ATTORNEYS FOR PLAINTIFF
Client Ref #: 20195125
CASE NO.: 21-CV-0046
AMERICAN EXPRESS NATIONAL BANK, IN THE Galveston County 122nd District Court
vs. Galveston COUNTY, TX
URSULA REED a/k/a U. DARLA REED,
SUPPORT FOR SUBSTITUTE SERVICE ORDER - TRCP 106
I, Ronald Walter Kirk , do state that the following is true and correct:
That I am over the age of eighteen, not a party to this suit, and have no interest in the outcome of the suit. I have met the criteria
and I am authorized to serve process in the State of Texas.
On January 14, 2021 at 9:11 AM , I received a Citation; Plaintiff's Original Petition to be delivered to URSULA REED a/k/a U. DARLA
REED at 13885 RED OAK CIR S , Mc Kinney, TX75071.
To my personal knowledge, based on the following attempts to deliver said documents to the Defendant(s), this is the most likely
location for Defendant to receive notice of suit.
2021-04-
11:51 13885 RED OAK CIR S , Mc Kinney, TX75071
09
AM Spoke to a male resident. Said subject was working but is usually home at night.
Friday
2021-04-
13885 RED OAK CIR S , Mc Kinney, TX75071
10 3:07 PM
No answer at door. No cars in driveway. Left contact info.
Saturday
2021-04- 13885 RED OAK CIR S , Mc Kinney, TX75071
12 9:29 AM Spoke to Krista, subjects daughter-in-law. Said subject was at work but will let her know l stopped
Monday by again.
2021-04-
13885 RED OAK CIR S , Mc Kinney, TX75071
13 7:08 PM
Spoke to subjects son. Said she was not home.
Tuesday
I have been unable to make personal delivery to URSULA REED a/k/a U. DARLA REED as reported in the above referenced
attempts to notify URSULA REED a/k/a U. DARLA REED of this suit. I believe URSULA REED a/k/a U. DARLA REED will receive
notification of this suit by delivering to any individual over the age of sixteen, or by affixing to the front entrance at 13885 RED
OAK CIR S , Mc Kinney, TX75071, the usual place of abode for URSULA REED a/k/a U. DARLA REED. The included photo(s) was
taken by me during my attempts to perfect service to the defendant and is provided in support of those attempts.
My name is Ronald Walter Kirk, my date of birth is 12/06/1958, and my EZ MESSENGER
address is 9210 S. Western Avenue Suite A-3
9210 S. Western Avenue Suite A-3, Oklahoma City, OK73139, USA. Oklahoma City, OK73139
I declare under penalty of perjury that the foregoing is true and correct. 214-748-4200
Executed in COLLIN County, State of TX on April 14, 2021. txupdates@ezmessenger.com
Client File #: 20195125
TX - The DeGrasse Law Firm, PC
PSC:18543 EXP:08/31/2022
Total Service Costs: 80.00
Preview
Filed: 4/20/2021 8:49 AM JOHN D. KINARD - District Clerk Galveston County, Texas Envelope No. 52619460 By: Lisa Kelly CASE NO.: 21-CV-0046 4/20/2021 9:00 AM AMERICAN EXPRESS NATIONAL BANK, IN THE Galveston County 122nd District Court Plaintiff(s), vs. Galveston COUNTY, TX URSULA REED a/k/a U. DARLA REED, Defendant(s). MOTION FOR RULE 106 SERVICE Plaintiff moves the Court to order service of Citation; Plaintiff's Original Petition on Defendant(s), URSULA REED a/k/a U. DARLA REED, by delivering to Defendant(s), URSULA REED a/k/a U. DARLA REED, as prescribed by Rule 106 of the T.R.C.P. Private Process Server, Ro n a l d Wa l te r Ki rk , licensed in the State of Texas with license number PS C : 18 5 4 3 EX P : 08 / 3 1 / 2 0 2 2 , has made 4 unsuccessful attempts and other efforts to personally serve Citation; Plaintiff's Original Petition to be served upon said Defendant(s) as indicated by the attached affidavit. Plaintiff requests the Court issue an order authorizing substituted service of Citation; Plaintiff's Original Petition as prescribed by Rule 106 of the T.R.C.P., by delivering a true and correct copy of the Citation; Plaintiff's Original Petition to anyone over the age of sixteen (16), or by affixing to the front entrance at the Defendant(s)'s usual place of abode, 13885 RED OAK CIR S , Mc K in n e y , T X 7 5 0 7 1 . Respectfully Submitted: /S/Donald D. DeGrasse _________________________________ THE DEGRASSE LAW FIRM, PC Donald DeGrasse State Bar No. 05641800 Eric M. Spence State Bar No. 24070658 Beatrice Grevel State Bar No. 00796677 Leonidia Leo Vidal Glasper State Bar No. 24111179 E-mail: attorneys@degrasselaw.com 1800 Bering Drive, Suite 1000 Houston, TX 77057 ATTORNEYS FOR PLAINTIFF Client Ref #: 20195125 CASE NO.: 21-CV-0046 AMERICAN EXPRESS NATIONAL BANK, IN THE Galveston County 122nd District Court vs. Galveston COUNTY, TX URSULA REED a/k/a U. DARLA REED, SUPPORT FOR SUBSTITUTE SERVICE ORDER - TRCP 106 I, Ronald Walter Kirk , do state that the following is true and correct: That I am over the age of eighteen, not a party to this suit, and have no interest in the outcome of the suit. I have met the criteria and I am authorized to serve process in the State of Texas. On January 14, 2021 at 9:11 AM , I received a Citation; Plaintiff's Original Petition to be delivered to URSULA REED a/k/a U. DARLA REED at 13885 RED OAK CIR S , Mc Kinney, TX75071. To my personal knowledge, based on the following attempts to deliver said documents to the Defendant(s), this is the most likely location for Defendant to receive notice of suit. 2021-04- 11:51 13885 RED OAK CIR S , Mc Kinney, TX75071 09 AM Spoke to a male resident. Said subject was working but is usually home at night. Friday 2021-04- 13885 RED OAK CIR S , Mc Kinney, TX75071 10 3:07 PM No answer at door. No cars in driveway. Left contact info. Saturday 2021-04- 13885 RED OAK CIR S , Mc Kinney, TX75071 12 9:29 AM Spoke to Krista, subjects daughter-in-law. Said subject was at work but will let her know l stopped Monday by again. 2021-04- 13885 RED OAK CIR S , Mc Kinney, TX75071 13 7:08 PM Spoke to subjects son. Said she was not home. Tuesday I have been unable to make personal delivery to URSULA REED a/k/a U. DARLA REED as reported in the above referenced attempts to notify URSULA REED a/k/a U. DARLA REED of this suit. I believe URSULA REED a/k/a U. DARLA REED will receive notification of this suit by delivering to any individual over the age of sixteen, or by affixing to the front entrance at 13885 RED OAK CIR S , Mc Kinney, TX75071, the usual place of abode for URSULA REED a/k/a U. DARLA REED. The included photo(s) was taken by me during my attempts to perfect service to the defendant and is provided in support of those attempts. My name is Ronald Walter Kirk, my date of birth is 12/06/1958, and my EZ MESSENGER address is 9210 S. Western Avenue Suite A-3 9210 S. Western Avenue Suite A-3, Oklahoma City, OK73139, USA. Oklahoma City, OK73139 I declare under penalty of perjury that the foregoing is true and correct. 214-748-4200 Executed in COLLIN County, State of TX on April 14, 2021. txupdates@ezmessenger.com Client File #: 20195125 TX - The DeGrasse Law Firm, PC PSC:18543 EXP:08/31/2022 Total Service Costs: 80.00