Preview
Electronically Filed
6/9/2023 9:54 AM
Our File No. 253 1Sf#a Richard
County Clerk
Case No. 17-CCV-058960 Fort Bend County, Texas
Discover Bank In the County Court at Law 5
Plaintiff
of
v
VICKI LHOWEN FORT BEND County Texas
Defendant(s)
APPLICATION FOR THE APPOINTMENT OF A RECEIVER
NOW COMES, Applicant, Discover Bank, Plaintiff-in judgment, who respectfully requests the Court grant this
Application for Appointment of Receiver and Turnover Relief and against Defendant(s) VICKIL HOWEN pursuant to 31.002
of the Texas Civil Practices and Remedies Code. In support of the application, Plaintiff alleges as follows:
A. JUDGMENT
On or about September 18, 2019, Plaintiff recovered a judgment against VICKI L HOWEN in this court. After all
just and lawful offsets, payments, and credits have been issued, the balance that remains unsatisfied on this judgment is
$12,388.58 as of June 5, 2023.
B. REQUESTED PROPERTY
The property made the basis of this application is strictly limited to cash on-hand and/or on-deposit at any financial
institution where the Defendant holds an account. As such, Applicant is not aware of any applicable exemptions under any
statute from the attachment, execution, or seizure of the requested property for the satisfaction of liabilities. Nothing herein
shall apply to any other form of property other than what is specifically described above, and as such, the property requested
cannot be reasonably attached or levied on by ordinary legal process. Plaintiff has reason to believe that Judgment Defendant
has a bank account holding non-exempt funds. Plaintiff served Judgment Defendant with Written - Post Judgment Discovery,
which included Requests for Admissions. Specifically, the Requests for Admissions included the following:
Request: Defendant has an active Bank account
Request: All assets owned by the Defendant are non-exempt property.
Please see Plaintiff's Unsworn Declaration in support of Application for the Appointment of a Receiver.
C. MOTION FOR APPOINTMENT OF RECEIVER
Plaintiff moves the Court to order Defendant to turn over the property identified above, with all documents and
Records related to that property, to the Receiver appointed hereafter at that Receiver’s address within five (5) days of the
entry of an Order herein.
D. APPOINTMENT OF RECEIVER
Plaintiff moves the Court to appoint Robert E. Jenkins; 2221 Justin Rd. #119-480; Flower Mound, TX 75028,
as receiver (Receiver) in this matter pursuant to TCPRC 31.002(b)(3) with limited authority to take possession of all requested
property, as identified above, that is on-hand and/or on-deposit with any financial institution where Defendant holds an
account, and pay the proceeds to the judgment creditor to the extent necessary to satisfy the judgment. The proposed powers,
duties, and responsibility of the Receiver are more particularly stated in the proposed order which is submitted
contemporaneously with this application. Exhibit 1- Resume.
E_COMPENSATION TO RECEIVER
Plaintiff moves that Defendant be ordered to pay Receiver twenty five (25) percent of the recoveries, as compensation
to the Receiver, and that such compensation (and out of pocket expenses directly related to the recovery) be paid, as taxable
court costs, in addition to the amount owed to Plaintiff.
F. PRAYER
Plaintiff requests an order granting this Application, and prays
A That a Receiver be appointed as contemplated by TCPRC 31.002 and the Receiver’s bond to be waived.
B That every Defendant and third party financial institution in which Plaintiff has an interest be ordered to
deliver the property, with necessary documents, properly endorsed for transfer to the Receiver and deliver
any information concerning said property to accounts.
That Plaintiff have judgment against Defendant for Receiver’s Fee; and
That Plaintiff is granted all further relief to which Plaintiff may be entitled.
Respectfully submitted:
RAUSCH STURM LLP
ATTORNEYS IN THE PRACTICE OF DEBT COLLECTION
kefe Wie
(CHRISTOPHER
KYLE WHITE, SBN 24103985,
15660 N. Dallas Parkway, Suite 350
Dallas TX 75248
Toll Free - (833) 917-4025 TTY: 711 Fax - Dallas (877) 492-5185
E-mail: LawfirmTX @rauschsturm.com
ATTORNEY FOR PLAINTIFF
2531563
Our File No. 2531563
Case No. 17-CCV-058960
Discover Bank In the County Court at Law 5
Plaintiff
of
v
VICKI LHOWEN FORT BEND County Texas
Defendant(s)
DECLARATION IN SUPPORT OF APPLICATION FOR APPOINTMENT OF
RECEIVER AND TURNOVER RELIEF
Pursuant to Tex. Civ. Prac. and Rem. Code § 132.001, which states 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.”, the undersigned attorney submits the following:
My name is ChristopherKyle
White my date of birth is —sand the office address of RAUSCH STURM LLP
is 15660 N. Dallas Parkway, Suite 350, Dallas, TX 75248, County of Dallas.
I declare under penalty of perjury that the following is true and correct:
Iam over twenty-one years of age, licensed to practice law in the State of Texas, am the attorney for Plaintiff and
competent to make this affidavit.
I have reviewed the file on the Defendant. Based on my review of the file and my general familiarity with this
account, I have personal knowledge of the account and to the best of my knowledge the matters stated herein are true.
Jam familiar with this case and collecting judgments, familiar with public information regarding the Defendant, and
confirm that attempts have been made to collect on the judgment balance. The property sought in this application
is not readily attachable by ordinary legal process as it is limited to cash on-hand and/or on-deposit with financial
institutions in accounts under the Defendant’s name.
I believe that this application for appointment of receiver and turnover relief is necessary because Defendant is
believed to have, based upon a review of the file, property that cannot be readily attached or levied on by ordinary
legal process and that is not exempt from attachment, execution, or seizure for the satisfaction of liabilities.
T have reviewed the file on the Defendant. Despite attempts to collect on this debt through reasonable collection
efforts, including but not limited to, sending post judgment discovery to the defendant on August 30, 2022.
Robert E. Jenkins is a citizen, resident, and qualified voter of the State of Texas. At the time of appointment, Robert
E. Jenkins is not a party, attorney, or other person interested in the action for appointment of a receiver. Robert E.
Jenkins will perform his duties faithfully, and in obedience of the Orders of the Court. A copy of Robert E. Jenkins’s
resume is attached hereto.
Defendant owns and has, or will have within its possession or control property interests, together with documents
relating to the property, which is not exempt from attachment, execution, or any other type of seizure for the
satisfaction of liabilities, and which cannot be readily attached or levied on by ordinary legal process.
Defendant’s non-exempt property which is subject to collection under the statute includes all right, title, interest and
documents of ownership to the property listed on the application.
T have reviewed the file on the Defendant and as of the date of this filing, no responses to post judgment discovery
have been received.
10. In addition, Plaintiff is entitled to the appointment of a Receiver as expressly provided by the Statue. Plaintiff is
entitled to have the Court require that Defendant be ordered to turnover and deliver to the Receiver all such requested
Property with all documents of ownership and to execute any and all documents needed to assign the property to the
Receiver. The Receiver should be authorized to take possession of the Property, and to pay the Plaintiff in the
amount sufficient to satisfy the Judgment and the additional court costs and fees awarded pursuant to bringing this
Application. Plaintiff is entitled to appointment of a Receiver with the powers set forth in detail on the Application
and proposed order submitted contemporaneously with said Application.
11 Compensation to Receiver. Plaintiff moves that the Court order Defendant to pay Receiver twenty five (25) percent
of the proceeds of any cash recovered, as compensation to the Receiver, and that such compensation shall be paid
by Receiver in addition to the amounts owed to Plaintiff. Plaintiff moves Defendant be ordered to pay Receiver’s
out of pocket expenses directly related to recovery of Property in this case. All such compensation be taxed as costs
in the case.
12. Bond. This is a post-judgment matter. Moreover, Robert E. Jenkins maintains a debt collector bond. Therefore, no
bond should be required for the Receiver.
Executed in Montgomery County, State of Texas, on 06/09/2023
aye le Ma
(CHRISTOPHER
KYLE WHITE, SBN 24103985
15660 N. Dallas Parkway, Suite 350
Dallas TX 75248
Toll Free - (833) 917-4025 TTY: 711 Fax - Dallas (877) 492-5185
E-mail: LawfirmTX @rauschsturm.com
ATTORNEY FOR PLAINTIFF
2531563
EXHIBIT 1
ROBERT E. JENKINS
2221 Justin Rd. #119-480 * Flower Mound, Texas 75028 * 214.220.2022 ¢ FrontDesk @JenkinsLaw.com
Attorney & Receiver
Robert E. Jenkins has been a licensed attorney for more than 20 years and began serving as a court-appointed receiver in 2012. He is a fulltime
post-judgment turnover receiver and has been appointed to aid in the recovery of nonexempt assets for the payment of judgments in thousands
of cases by 900+ courts in 180+ counties throughout Texas. Receiver Jenkins is dedicated to his duty of serving as an agent of the Court
within the strictures established by the receivership orders and treating all defendants with dignity and respect.
RECEIVER RESULTS:
Receiver Jenkins has facilitated more than 2,000 judgments being paid through receiverships.
25% RECEIVER FEE:
It is Receiver Jenkins’ expert opinion that the customary and usual post-judgment tumover receiver fee is 25% of the funds recovered during the
receivership, subject to a later determination as to reasonableness by the Court or Judgment Defendant's written agreement for the fee to be
paid.
BACKGROUND:
Prior to Receiver Jenkins becoming a fulltime post-judgment turnover receiver, he represented banks, investors, and business owners in the
recovery of consumer and commercial debt, bank garnishment defense, and judgment enforcement. Having represented national and state banks,
he is familiar with institutional protocols and his office has implemented stringent security measures to protect sensitive financial data.
EDUCATION:
UCLA School of Law, Los Angeles, California, Juris Doctorate, 2000
Honors: UCLA Moot Court Honors Program, Appellate Advocate
American Jurisprudence Award, Legal Writing
Teaching Assistant, Legal Writing
Leadership: UCLA Moot Court Honors Program, President
The University of Texas, Austin, Texas, Bachelor of Journalism with High Honors, 1997
PUBLICATIONS:
Running Aground in a Sea of Complex Litigation: A Case Comment on the Exxon Valdez Litigation 18 UCLA J.ENVTL.L. & POL'Y
151 (2000)
LICENSES AND ADMISSIONS:
State Bar of Texas, admitted November 2002 (TX Bar # 24036842)
State Bar of California, admitted December 2000 (CA Bar # 211361)
U.S. Court of Appeals for the Fifth Circuit and the Ninth Circuit
US. District Court, Northern and Eastern Districts of TX; Southern, Eastern, and Central Districts of CA
MEMBERSHIPS:
Texas Association of Turnover Receivers
Texas Creditor’s Bar Association
Consumer and Commercial Law, TX Bar Section
PROFESSIONAL HONORS:
Texas Rising Stars, 2010
SEMINAR SPEAKER:
Receiverships in Justice Court, State Bar of Texas Justice Court Section - February 7, 2020
Turnover Order/Receivership Training Program at N. TX JP & Constables Assoc. - Decatur, TX- March 28, 2019
SIGNIFICANT LEGAL EXPERIENCE:
2012 - Present Jenkins Law Firm, PC, Flower Mound, Texas:
Receiver / Principal Shareholder: Serves Judges throughout Texas exclusively as a fulltime courtappointed
post-judgment turnover receiver.
2007 - 2012 Jenkins | Babb, LLP and Robert E. Jenkins, P.C., Dallas, Texas
Managing Partner: Commercial and consumer collections, garnishment defense, foreclosures, enforcing judgments,
and serving as court-appointed receiver.
2003-2007 Vial, Hamilton, Koch & Knox, LLP, Dallas, Texas
Litigation Associate: Practiced commercial and business litigation in the recovery of consumer and commercial debt,
foreclosures, and judgment enforcement.
2000-2002 Seltzer Caplan McMahon Vitek, San Diego, California
Litigation Associate: Practiced business and real estate litigation.
CERTIFICATE OF SERVICE
This is to CERTIFY that, in compliance with the provisions of the Texas Rules of Civil Procedure, a true
and correct copy of the foregoing Plaintiff's Application for Appointment of a Receiver has been served on the
following named person by First Class Mail to:
VICKI L HOWEN
TOMBALL TX 77375
Respectfully submitted;
RAUSCH STURM LLP
ATTORNEYS IN THE PRACTICE OF DEBT COLLECTION
By kefe Wie
(CHRISTOPHER
KYLE WHITE, SBN 24103985
15660 N. Dallas Parkway, Suite 350
Dallas TX 75248
Toll Free - (833) 917-4025 TTY: 711 Fax - Dallas (877) 492-5185
E-mail: LawfirmTX @rauschsturm.com
ATTORNEY FOR PLAINTIFF
2531563
Preview
Electronically Filed 6/9/2023 9:54 AM Our File No. 253 1Sf#a Richard County Clerk Case No. 17-CCV-058960 Fort Bend County, Texas Discover Bank In the County Court at Law 5 Plaintiff of v VICKI LHOWEN FORT BEND County Texas Defendant(s) APPLICATION FOR THE APPOINTMENT OF A RECEIVER NOW COMES, Applicant, Discover Bank, Plaintiff-in judgment, who respectfully requests the Court grant this Application for Appointment of Receiver and Turnover Relief and against Defendant(s) VICKIL HOWEN pursuant to 31.002 of the Texas Civil Practices and Remedies Code. In support of the application, Plaintiff alleges as follows: A. JUDGMENT On or about September 18, 2019, Plaintiff recovered a judgment against VICKI L HOWEN in this court. After all just and lawful offsets, payments, and credits have been issued, the balance that remains unsatisfied on this judgment is $12,388.58 as of June 5, 2023. B. REQUESTED PROPERTY The property made the basis of this application is strictly limited to cash on-hand and/or on-deposit at any financial institution where the Defendant holds an account. As such, Applicant is not aware of any applicable exemptions under any statute from the attachment, execution, or seizure of the requested property for the satisfaction of liabilities. Nothing herein shall apply to any other form of property other than what is specifically described above, and as such, the property requested cannot be reasonably attached or levied on by ordinary legal process. Plaintiff has reason to believe that Judgment Defendant has a bank account holding non-exempt funds. Plaintiff served Judgment Defendant with Written - Post Judgment Discovery, which included Requests for Admissions. Specifically, the Requests for Admissions included the following: Request: Defendant has an active Bank account Request: All assets owned by the Defendant are non-exempt property. Please see Plaintiff's Unsworn Declaration in support of Application for the Appointment of a Receiver. C. MOTION FOR APPOINTMENT OF RECEIVER Plaintiff moves the Court to order Defendant to turn over the property identified above, with all documents and Records related to that property, to the Receiver appointed hereafter at that Receiver’s address within five (5) days of the entry of an Order herein. D. APPOINTMENT OF RECEIVER Plaintiff moves the Court to appoint Robert E. Jenkins; 2221 Justin Rd. #119-480; Flower Mound, TX 75028, as receiver (Receiver) in this matter pursuant to TCPRC 31.002(b)(3) with limited authority to take possession of all requested property, as identified above, that is on-hand and/or on-deposit with any financial institution where Defendant holds an account, and pay the proceeds to the judgment creditor to the extent necessary to satisfy the judgment. The proposed powers, duties, and responsibility of the Receiver are more particularly stated in the proposed order which is submitted contemporaneously with this application. Exhibit 1- Resume. E_COMPENSATION TO RECEIVER Plaintiff moves that Defendant be ordered to pay Receiver twenty five (25) percent of the recoveries, as compensation to the Receiver, and that such compensation (and out of pocket expenses directly related to the recovery) be paid, as taxable court costs, in addition to the amount owed to Plaintiff. F. PRAYER Plaintiff requests an order granting this Application, and prays A That a Receiver be appointed as contemplated by TCPRC 31.002 and the Receiver’s bond to be waived. B That every Defendant and third party financial institution in which Plaintiff has an interest be ordered to deliver the property, with necessary documents, properly endorsed for transfer to the Receiver and deliver any information concerning said property to accounts. That Plaintiff have judgment against Defendant for Receiver’s Fee; and That Plaintiff is granted all further relief to which Plaintiff may be entitled. Respectfully submitted: RAUSCH STURM LLP ATTORNEYS IN THE PRACTICE OF DEBT COLLECTION kefe Wie (CHRISTOPHER KYLE WHITE, SBN 24103985, 15660 N. Dallas Parkway, Suite 350 Dallas TX 75248 Toll Free - (833) 917-4025 TTY: 711 Fax - Dallas (877) 492-5185 E-mail: LawfirmTX @rauschsturm.com ATTORNEY FOR PLAINTIFF 2531563 Our File No. 2531563 Case No. 17-CCV-058960 Discover Bank In the County Court at Law 5 Plaintiff of v VICKI LHOWEN FORT BEND County Texas Defendant(s) DECLARATION IN SUPPORT OF APPLICATION FOR APPOINTMENT OF RECEIVER AND TURNOVER RELIEF Pursuant to Tex. Civ. Prac. and Rem. Code § 132.001, which states 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.”, the undersigned attorney submits the following: My name is ChristopherKyle White my date of birth is —sand the office address of RAUSCH STURM LLP is 15660 N. Dallas Parkway, Suite 350, Dallas, TX 75248, County of Dallas. I declare under penalty of perjury that the following is true and correct: Iam over twenty-one years of age, licensed to practice law in the State of Texas, am the attorney for Plaintiff and competent to make this affidavit. I have reviewed the file on the Defendant. Based on my review of the file and my general familiarity with this account, I have personal knowledge of the account and to the best of my knowledge the matters stated herein are true. Jam familiar with this case and collecting judgments, familiar with public information regarding the Defendant, and confirm that attempts have been made to collect on the judgment balance. The property sought in this application is not readily attachable by ordinary legal process as it is limited to cash on-hand and/or on-deposit with financial institutions in accounts under the Defendant’s name. I believe that this application for appointment of receiver and turnover relief is necessary because Defendant is believed to have, based upon a review of the file, property that cannot be readily attached or levied on by ordinary legal process and that is not exempt from attachment, execution, or seizure for the satisfaction of liabilities. T have reviewed the file on the Defendant. Despite attempts to collect on this debt through reasonable collection efforts, including but not limited to, sending post judgment discovery to the defendant on August 30, 2022. Robert E. Jenkins is a citizen, resident, and qualified voter of the State of Texas. At the time of appointment, Robert E. Jenkins is not a party, attorney, or other person interested in the action for appointment of a receiver. Robert E. Jenkins will perform his duties faithfully, and in obedience of the Orders of the Court. A copy of Robert E. Jenkins’s resume is attached hereto. Defendant owns and has, or will have within its possession or control property interests, together with documents relating to the property, which is not exempt from attachment, execution, or any other type of seizure for the satisfaction of liabilities, and which cannot be readily attached or levied on by ordinary legal process. Defendant’s non-exempt property which is subject to collection under the statute includes all right, title, interest and documents of ownership to the property listed on the application. T have reviewed the file on the Defendant and as of the date of this filing, no responses to post judgment discovery have been received. 10. In addition, Plaintiff is entitled to the appointment of a Receiver as expressly provided by the Statue. Plaintiff is entitled to have the Court require that Defendant be ordered to turnover and deliver to the Receiver all such requested Property with all documents of ownership and to execute any and all documents needed to assign the property to the Receiver. The Receiver should be authorized to take possession of the Property, and to pay the Plaintiff in the amount sufficient to satisfy the Judgment and the additional court costs and fees awarded pursuant to bringing this Application. Plaintiff is entitled to appointment of a Receiver with the powers set forth in detail on the Application and proposed order submitted contemporaneously with said Application. 11 Compensation to Receiver. Plaintiff moves that the Court order Defendant to pay Receiver twenty five (25) percent of the proceeds of any cash recovered, as compensation to the Receiver, and that such compensation shall be paid by Receiver in addition to the amounts owed to Plaintiff. Plaintiff moves Defendant be ordered to pay Receiver’s out of pocket expenses directly related to recovery of Property in this case. All such compensation be taxed as costs in the case. 12. Bond. This is a post-judgment matter. Moreover, Robert E. Jenkins maintains a debt collector bond. Therefore, no bond should be required for the Receiver. Executed in Montgomery County, State of Texas, on 06/09/2023 aye le Ma (CHRISTOPHER KYLE WHITE, SBN 24103985 15660 N. Dallas Parkway, Suite 350 Dallas TX 75248 Toll Free - (833) 917-4025 TTY: 711 Fax - Dallas (877) 492-5185 E-mail: LawfirmTX @rauschsturm.com ATTORNEY FOR PLAINTIFF 2531563 EXHIBIT 1 ROBERT E. JENKINS 2221 Justin Rd. #119-480 * Flower Mound, Texas 75028 * 214.220.2022 ¢ FrontDesk @JenkinsLaw.com Attorney & Receiver Robert E. Jenkins has been a licensed attorney for more than 20 years and began serving as a court-appointed receiver in 2012. He is a fulltime post-judgment turnover receiver and has been appointed to aid in the recovery of nonexempt assets for the payment of judgments in thousands of cases by 900+ courts in 180+ counties throughout Texas. Receiver Jenkins is dedicated to his duty of serving as an agent of the Court within the strictures established by the receivership orders and treating all defendants with dignity and respect. RECEIVER RESULTS: Receiver Jenkins has facilitated more than 2,000 judgments being paid through receiverships. 25% RECEIVER FEE: It is Receiver Jenkins’ expert opinion that the customary and usual post-judgment tumover receiver fee is 25% of the funds recovered during the receivership, subject to a later determination as to reasonableness by the Court or Judgment Defendant's written agreement for the fee to be paid. BACKGROUND: Prior to Receiver Jenkins becoming a fulltime post-judgment turnover receiver, he represented banks, investors, and business owners in the recovery of consumer and commercial debt, bank garnishment defense, and judgment enforcement. Having represented national and state banks, he is familiar with institutional protocols and his office has implemented stringent security measures to protect sensitive financial data. EDUCATION: UCLA School of Law, Los Angeles, California, Juris Doctorate, 2000 Honors: UCLA Moot Court Honors Program, Appellate Advocate American Jurisprudence Award, Legal Writing Teaching Assistant, Legal Writing Leadership: UCLA Moot Court Honors Program, President The University of Texas, Austin, Texas, Bachelor of Journalism with High Honors, 1997 PUBLICATIONS: Running Aground in a Sea of Complex Litigation: A Case Comment on the Exxon Valdez Litigation 18 UCLA J.ENVTL.L. & POL'Y 151 (2000) LICENSES AND ADMISSIONS: State Bar of Texas, admitted November 2002 (TX Bar # 24036842) State Bar of California, admitted December 2000 (CA Bar # 211361) U.S. Court of Appeals for the Fifth Circuit and the Ninth Circuit US. District Court, Northern and Eastern Districts of TX; Southern, Eastern, and Central Districts of CA MEMBERSHIPS: Texas Association of Turnover Receivers Texas Creditor’s Bar Association Consumer and Commercial Law, TX Bar Section PROFESSIONAL HONORS: Texas Rising Stars, 2010 SEMINAR SPEAKER: Receiverships in Justice Court, State Bar of Texas Justice Court Section - February 7, 2020 Turnover Order/Receivership Training Program at N. TX JP & Constables Assoc. - Decatur, TX- March 28, 2019 SIGNIFICANT LEGAL EXPERIENCE: 2012 - Present Jenkins Law Firm, PC, Flower Mound, Texas: Receiver / Principal Shareholder: Serves Judges throughout Texas exclusively as a fulltime courtappointed post-judgment turnover receiver. 2007 - 2012 Jenkins | Babb, LLP and Robert E. Jenkins, P.C., Dallas, Texas Managing Partner: Commercial and consumer collections, garnishment defense, foreclosures, enforcing judgments, and serving as court-appointed receiver. 2003-2007 Vial, Hamilton, Koch & Knox, LLP, Dallas, Texas Litigation Associate: Practiced commercial and business litigation in the recovery of consumer and commercial debt, foreclosures, and judgment enforcement. 2000-2002 Seltzer Caplan McMahon Vitek, San Diego, California Litigation Associate: Practiced business and real estate litigation. CERTIFICATE OF SERVICE This is to CERTIFY that, in compliance with the provisions of the Texas Rules of Civil Procedure, a true and correct copy of the foregoing Plaintiff's Application for Appointment of a Receiver has been served on the following named person by First Class Mail to: VICKI L HOWEN TOMBALL TX 77375 Respectfully submitted; RAUSCH STURM LLP ATTORNEYS IN THE PRACTICE OF DEBT COLLECTION By kefe Wie (CHRISTOPHER KYLE WHITE, SBN 24103985 15660 N. Dallas Parkway, Suite 350 Dallas TX 75248 Toll Free - (833) 917-4025 TTY: 711 Fax - Dallas (877) 492-5185 E-mail: LawfirmTX @rauschsturm.com ATTORNEY FOR PLAINTIFF 2531563