On January 28, 2020 a
Hearing
was filed
involving a dispute between
American Eagle Tax Services Inc,
Peter S Chow Cpa Inc,
and
Amador, Miguel A,
Amador, Tirza Denisse,
Mundo Tax & Insurance Services Inc,
for CNTR CNSMR COM DEBT
in the District Court of Dallas County.
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I
8/4/2020 3:39 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Kellie J uricek DEPUTY
Cause No.: DC-20-01565
American Eagle Tax Services, Inc. § The State of Texas
d/b/a American Tax Service, and Peter §
S. Chow CPA, Ine. d/b/a American Tax §
Service §
-Plaintiffs §
vs. § Dallas County, Texas
Tirza Denisse Amador §
aka Tirza Casanova § 14" Judicial District Court
-Defendant §
Declaration of Brian W. Erikson
For Plaintiffs’ Amended Motion to Continue Hearing on
Defendant’s Motion to Dissolve Temporary Injunction
I, Brian W. Erikson, make the following declaration in connection with the Plaintiffs’
Amended Motion to Continue Hearing on Defendant’s Motion to Dissolve Temporary Injunction.
lam over the age of 21, and am competent to make this Declaration The statements which follow
are based on my personal knowledge and are true and correct.
I am an attorney at law, licensed by the Texas Supreme Court. I represent the Plaintiffs,
American Eagle Tax Services, Inc. d/ba American Tax Service, and Peter S. Chow CPA, Inc. d/b/a
American Tax Service, in the above captioned and numbered suit (“Suit”).
In connection with my representation of the Plaintiffs in the Suit, I prepared and filed
motions concerning the Defendant, Tirza Denisse Amador aka Tirza Casanova Casanova. The
motions included:
1 Plaintiffs’ Motion to Set Defendant’s Motions to Quash for Hearing;
2 Plaintiffs’ Motion to Compel Production of Documents;
3 Plaintiffs’ Motion to Compel Answers to Interrogatories; and
Declaration of Brian W. Erikson - For Plaintiffs’ Amended Motion to Continue Hearing on
Defendant’s Motion to Dissolve Temporary Injunction - Page 1
4 Plaintiffs’ Amended Motion for Sanctions.
Defendant had set a hearing on her Motion to Compel Separate Responses to Defendant’s
Written Discovery Requests on August 10, 2020.
On July 30, 2020, I spent about an hour and a half on the telephone with Defendant’s
attorney, Sam Johnson, in an effort to resolve the five motions. Among other things that I discussed
with Defendant’s attorney was Defendant’s setting up of “virtual offices” with no physical presence
and with Defendant’s base of operations remaining in Arlington, Texas. Defendant’s attorney told
me that Defendant had set up a “virtual office” at 3000 Custer Road, Plano, Texas 75075, but was
not recruiting customers from that area.
We reached a resolution on the first three motions and Defendant’s motion. We
memorialized the resolutions in a Rule 11 Agreement, which filed with the Court on July 30, 2020.
Among other things, the Rule 11 Agreement stated: “The parties will cancel their hearings currently
set for August 3, 2020 and August 10, 2020 pending”.
On August 3, 2020, Defendant set a hearing on Defendant’s Motion to Dissolve Temporary
Injunction on August 10, 2020, without consultation with me as the date.
Jurat
My name is Brian W. Erikson, my date of birth is August 5, 1953, and my address is P.O.
Box 141253, Dallas, Texas 75214. I declare under penalty of perjury that the foregoing is true and
correct.
Executed in Dallas County, State of Texas, on the ly 0} ugust. 2020
Brian W. Erikson
Declaration of Brian W. Erikson - For Plaintiffs’ Amended Motion to Continue Hearing on
Defendant’s Motion to Dissolve Temporary Injunction - Page 2
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.
Envelope ID: 45091349
Status as of 08/05/2020 09:24:04 AM -05:00
Associated Case Party: TIRZADENISSEAMADOR
Name BarNumber Email TimestampSubmitted Status
Carrie Lewis Carrie@Gus-Gilbert.com 8/4/2020 3:39:55 PM SENT
Amos DPettis Amos@Gus-Gilbert.com 8/4/2020 3:39:55 PM SENT
Elizabeth J.Rogatski elizabeth@johnsonsparks.com 8/4/2020 3:39:55 PM SENT
Samuel HJohnson sam@johnsonsparks.com 8/4/2020 3:39:55 PM SENT
Associated Case Party: AMERICAN EAGLE TAX SERVICES INC
Name BarNumber | Email TimestampSubmitted Status
Brian W. Erikson | 6643800 Brian.Erikson@eriksonfirm.com | 8/4/2020 3:39:55 PM SENT
Associated Case Party: PETER S CHOW CPA INC
Name BarNumber Email TimestampSubmitted Status
Brian W. Erikson | 6643800 Brian.Erikson@eriksonfirm.com | 8/4/2020 3:39:55 PM SENT
Document Filed Date
August 04, 2020
Case Filing Date
January 28, 2020
Category
CNTR CNSMR COM DEBT
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I 8/4/2020 3:39 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Kellie J uricek DEPUTY Cause No.: DC-20-01565 American Eagle Tax Services, Inc. § The State of Texas d/b/a American Tax Service, and Peter § S. Chow CPA, Ine. d/b/a American Tax § Service § -Plaintiffs § vs. § Dallas County, Texas Tirza Denisse Amador § aka Tirza Casanova § 14" Judicial District Court -Defendant § Declaration of Brian W. Erikson For Plaintiffs’ Amended Motion to Continue Hearing on Defendant’s Motion to Dissolve Temporary Injunction I, Brian W. Erikson, make the following declaration in connection with the Plaintiffs’ Amended Motion to Continue Hearing on Defendant’s Motion to Dissolve Temporary Injunction. lam over the age of 21, and am competent to make this Declaration The statements which follow are based on my personal knowledge and are true and correct. I am an attorney at law, licensed by the Texas Supreme Court. I represent the Plaintiffs, American Eagle Tax Services, Inc. d/ba American Tax Service, and Peter S. Chow CPA, Inc. d/b/a American Tax Service, in the above captioned and numbered suit (“Suit”). In connection with my representation of the Plaintiffs in the Suit, I prepared and filed motions concerning the Defendant, Tirza Denisse Amador aka Tirza Casanova Casanova. The motions included: 1 Plaintiffs’ Motion to Set Defendant’s Motions to Quash for Hearing; 2 Plaintiffs’ Motion to Compel Production of Documents; 3 Plaintiffs’ Motion to Compel Answers to Interrogatories; and Declaration of Brian W. Erikson - For Plaintiffs’ Amended Motion to Continue Hearing on Defendant’s Motion to Dissolve Temporary Injunction - Page 1 4 Plaintiffs’ Amended Motion for Sanctions. Defendant had set a hearing on her Motion to Compel Separate Responses to Defendant’s Written Discovery Requests on August 10, 2020. On July 30, 2020, I spent about an hour and a half on the telephone with Defendant’s attorney, Sam Johnson, in an effort to resolve the five motions. Among other things that I discussed with Defendant’s attorney was Defendant’s setting up of “virtual offices” with no physical presence and with Defendant’s base of operations remaining in Arlington, Texas. Defendant’s attorney told me that Defendant had set up a “virtual office” at 3000 Custer Road, Plano, Texas 75075, but was not recruiting customers from that area. We reached a resolution on the first three motions and Defendant’s motion. We memorialized the resolutions in a Rule 11 Agreement, which filed with the Court on July 30, 2020. Among other things, the Rule 11 Agreement stated: “The parties will cancel their hearings currently set for August 3, 2020 and August 10, 2020 pending”. On August 3, 2020, Defendant set a hearing on Defendant’s Motion to Dissolve Temporary Injunction on August 10, 2020, without consultation with me as the date. Jurat My name is Brian W. Erikson, my date of birth is August 5, 1953, and my address is P.O. Box 141253, Dallas, Texas 75214. I declare under penalty of perjury that the foregoing is true and correct. Executed in Dallas County, State of Texas, on the ly 0} ugust. 2020 Brian W. Erikson Declaration of Brian W. Erikson - For Plaintiffs’ Amended Motion to Continue Hearing on Defendant’s Motion to Dissolve Temporary Injunction - Page 2 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. Envelope ID: 45091349 Status as of 08/05/2020 09:24:04 AM -05:00 Associated Case Party: TIRZADENISSEAMADOR Name BarNumber Email TimestampSubmitted Status Carrie Lewis Carrie@Gus-Gilbert.com 8/4/2020 3:39:55 PM SENT Amos DPettis Amos@Gus-Gilbert.com 8/4/2020 3:39:55 PM SENT Elizabeth J.Rogatski elizabeth@johnsonsparks.com 8/4/2020 3:39:55 PM SENT Samuel HJohnson sam@johnsonsparks.com 8/4/2020 3:39:55 PM SENT Associated Case Party: AMERICAN EAGLE TAX SERVICES INC Name BarNumber | Email TimestampSubmitted Status Brian W. Erikson | 6643800 Brian.Erikson@eriksonfirm.com | 8/4/2020 3:39:55 PM SENT Associated Case Party: PETER S CHOW CPA INC Name BarNumber Email TimestampSubmitted Status Brian W. Erikson | 6643800 Brian.Erikson@eriksonfirm.com | 8/4/2020 3:39:55 PM SENT