Complaint,Petition: Channel Partners Capital, LLC v. Sand Tech Management, LLC and John Taylor and Allegiance Bank N/K/A Stellar Bancorp, Inc.

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                                CAUSE NO.

     CHANNEL PARTNERS CAPITAL, LLC                                           IN THE DISTRICT COURT
       Plaintiff

     Vv

     SAND TECH MANAGEMENT, LLC
     AND JOHN TAYLOR
       Defendants                                                            457" JUDICIAL DISTRICT

     AND

     ALLEGIANCE BANK N/K/A STELLAR
     BANCORP, INC.
       Garnishee                                                    MONTGOMERY COUNTY, TEXAS


                  APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT


              1       Parties. Channel Partners Capital, LLC, Plaintiff in garnishment, whose address

is        10900    Wayzata     Boulevard,   Suite   300,   Minnetonka,   Minnesota   55305,   makes   this

Application for Writ of Garnishment after Judgment. Garnishee is Allegiance Bank n/k/a Stellar

Bancorp, Inc., who may be served with citation by serving its Registered Agent, Capitol

Corporate Services, Inc., at 1501 S. Mopac Expy, Suite 220, Austin, Texas 78746.

             2.       Facts.   Plaintiff has a valid, subsisting judgment against Defendants Sand Tech

Management, LLC and John Taylor in Cause No. 42-CV-23-730, in the 5" Judicial District

Court, Lyon County, Minnesota, which was rendered on July 19, 2023. The judgment was

domesticated in the State of Texas Cause No. 23-08-12228, in the 457" Judicial District Court,

Montgomery County, Texas on August 23, 2023. The amount on this judgment is $142,061.25 in

principal.

             Defendant Sand Tech Management, LLC’s mailing address is 25211 Grogans Mill Road,

Suite 350, Spring, Texas 77380.
Defendant John Taylor’s mailing address is       11211 Bonham Rand Road, Dripping Springs,

Texas 78620.

        Within Plaintiff's knowledge, Defendants do not possess property in Texas subject to

execution sufficient to satisfy the judgment. This garnishment is not sought to injure Defendants

or Garnishee.

        3       Affidavit. Plaintiff is entitled to the issuance of a writ of gamishment on the grounds

stated in the attached affidavit. The affidavit is incorporated in this application by reference.

        4       Prayer. Plaintiff prays that:

                        A writ of garnishment be issued directed to Garnishee;

                        Plaintiff be granted judgment against Gamishee for the amount now due on.

                        Plaintiff's judgment already rendered against Defendants, together with

                        interest and costs of the suit in the original case and in this garnishment

                       proceeding;

                        Plaintiff be granted judgment for pre-judgment and post-judgment interest

                       at the highest rate allowed by law; and

                       Plaintiff be granted all further relief to which Plaintiff may be entitled.
Respectfully Submitted,
LAM, LYN & PHILIP, P.C.
6363 Woodway Drive, Suite 975
Houston, Texas 77057
Telephone (713) 981-0900
=] "¢


Anita Jamali
State Bar No. 24110044
ajamali@llppc-law.com
Kurt L. Lyn
State Bar No. 00786078
klyn@llppe-law.com
Elizabeth Briscoe
State Bar No. 24107075
ebriscoe@llppc-law.com
Joni M. Fraser
State Bar No. 24089878
jfraser@lIppe-law.com
Attorneys for Plaintiff
CAUSE NO.

 CHANNEL PARTNERS CAPITAL, LLC                                           IN THE DISTRICT COURT
   Plaintiff

 Vv

 SAND TECH MANAGEMENT, LLC
 AND JOHN TAYLOR
   Defendants                                                            457" JUDICIAL DISTRICT

 AND

 ALLEGIANCE BANK N/K/A STELLAR
 BANCORP, INC.
   Garnishee                                                  MONTGOMERY COUNTY, TEXAS


           AFFIDAVIT FOR WRIT OF GARNISHMENT AFTER JUDGMENT


       BEFORE ME, the undersigned authority, on this day personally appeared Anita Jamali,

who swore on oath that the following facts are true:

       “T am Plaintiff Channel Partners Capital, LLC’s attorney of record in this cause. I am

authorized to make this affidavit and application for a writ of garnishment in this cause.

       I have personal knowledge of the facts stated in this affidavit, and they are true and correct.

       Plaintiff owns a judgment against Defendants, Sand Tech Management, LLC and John

Taylor, which was rendered on July 19, 2023, by the 5'" Judicial District Court, Lyon County,

Minnesota. The judgment is valid and subsisting, and a supersedeas bond has not been approved

and filed to suspend execution of the judgment. The amount on this judgment is $142,061.25 in

principal, said amount to include prejudgment interest and costs and disbursements.

       Within my knowledge, Defendants do not possess property in Texas subject to execution

sufficient to satisfy the judgment. My knowledge is based on a diligent search of the asset and

property records of Defendants in the Westlaw database. This garnishment is not sought to injure
Defendants or Garnishee.

       I have reason to believe and do believe that Garnishee has property belonging to the

Defendants or is indebted to the Defendants. This belief is based on Plaintiff's due diligence.”




                                                                      [Nadel
                                                                Anita Jémali, Afffant


       SIGNED under oath before me on this a 0                 day of September 2023.

                               ee
                    ss               MAYRA MUNOZ
                               Notary Public, State of Texas
                                Comm. Expires 04-11-2026
                                                                                 (Vino,
                                                                Notary Pulllic, State of Texad_/
                     mi   SE      Notary ID 131083165