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Electronically Submitted
6/10/2019 12:31 PM
Hidalgo County Clerk
Accepted by: Aurelio Aleman
CAUSE NO. CL-l6.4081.F
DSI MEDICAL SERVICES INC, $ IN THE COUNTY COURT
PLAINTIFF', s
$
vs. $ AT LAW
$
EDNA SANCHEZ DBA INFINITY $
DRUG & ALCOHOL SCREENING, $
DEFENDANT. s HIDALGO COUNTY, TEXAS
PLAINTIFF'S APPLICATION FOR TURNOVER RELIEF
AND APPOINTMENT OF A RECEIVER
1. Parties. Applicant, DSI MEDICAL SERVICES INC, Plaintiff and Judgment Creditor in
this this Application for Tumover Relief and Appointment of a
cause, requests that the Court grant
Receiver against EDNA SANCHEZ DBA INFINITY DRUG &
ALCOHOL SCREENING,
Defendant and Judgment Debtor.
2. Judgment. Plaintiff recovered judgment against Defendant in this cause.
3. Property Subject to Turnover. Pursuant to Texas Civil Practice and Remedies Code
Chapter 31.002, Plaintiff alleges that all remedies available at law or in equity to it are inadequate and
the Court has the authority to order the judgment debtor to turn over any and all non-exempt property,
including any checking or savings account in the name of the judgment debtor, shares of stock in the
name of the judgment debtor, all dividends and interest earned from stock, bonds, certificates of deposit,
all accounts receivable, notes receivable, cash income of a going business, interests in joint ventures or
partnerships, right to payment of commissions from a future event, firearms, deer stands, atv's, boats,
trailers, and motors, documentation regarding hunting or fishing leases or rights or the rights to time
share units or the use of property, tickets to events, like ballet or sporting events, proof of spa or club
memberships, royalties from copyrights and patents, royalties from oil and gas ventures whether in the
jurisdiction of the court and whether present or future, all property secreted by the debtor, all liens to
secure performance, and income tax refunds in the debtor's name or to the debtor's account whether in
trust or by direct deposit and to further provide the receiver with an accounting every month until the
judgment is paid. This property cannot readily be attached or levied on by ordinary legal process. This
property is not exempt under any statute from attachment, execution, or seizure for the satisfaction of
liabilities. See Exhibit "A'attached hereto and incorporated herein by reference.
4. Receiver. Plaintiff requests the Court appoint Paul R. Wilson, whose address is 323 West
Cano Street, Second Floor, Edinburg, Texas 78539 (telephone number (956) 316-0545; fax number
(956) 316-0747) as receiver.
5. Attorney's Fees. Pluntiff is entitled to recover reasonable attorney's fees and costs.
Reasonable fees for the attorney's services rendered and to be rendered arc at least $1,000.00.
6. Prayer. Plaintiff prays that the Court:
a. set this matter for hearing;
Electronically Submitted
6/10/2019 12:31 PM
Hidalgo County Clerk
Accepted by: Aurelio Aleman
b. appoint Paul R. Wilson as receiver;
b. issue the orders requested in this application;
c. grant Plaintiff at least $1,000.00 as reasonable attorney's fees;
d. grant Plaintiff reasonable expenses incurred in obtaining these orders; and
e. grant all further relief to which Plaintiff may be entitled.
Re spectfully submitted,
BARNETT & GARCIA, PLLC
A Professional Limited Liability Company
3821 Juniper Trace, Suite 108
Austin, Texas 78738
TELEPHONE: (5 12) 266-8830
FACSIMILE: (5 12) 266-8803
MilAA
Matias Eduardo Garcra
State Bar No.24012675
matt@b arnettgarc i a. com
Sean S.V. Homrig
State Bar No.24062789
sean@bamettgarcia. com
Preview
Electronically Submitted 6/10/2019 12:31 PM Hidalgo County Clerk Accepted by: Aurelio Aleman CAUSE NO. CL-l6.4081.F DSI MEDICAL SERVICES INC, $ IN THE COUNTY COURT PLAINTIFF', s $ vs. $ AT LAW $ EDNA SANCHEZ DBA INFINITY $ DRUG & ALCOHOL SCREENING, $ DEFENDANT. s HIDALGO COUNTY, TEXAS PLAINTIFF'S APPLICATION FOR TURNOVER RELIEF AND APPOINTMENT OF A RECEIVER 1. Parties. Applicant, DSI MEDICAL SERVICES INC, Plaintiff and Judgment Creditor in this this Application for Tumover Relief and Appointment of a cause, requests that the Court grant Receiver against EDNA SANCHEZ DBA INFINITY DRUG & ALCOHOL SCREENING, Defendant and Judgment Debtor. 2. Judgment. Plaintiff recovered judgment against Defendant in this cause. 3. Property Subject to Turnover. Pursuant to Texas Civil Practice and Remedies Code Chapter 31.002, Plaintiff alleges that all remedies available at law or in equity to it are inadequate and the Court has the authority to order the judgment debtor to turn over any and all non-exempt property, including any checking or savings account in the name of the judgment debtor, shares of stock in the name of the judgment debtor, all dividends and interest earned from stock, bonds, certificates of deposit, all accounts receivable, notes receivable, cash income of a going business, interests in joint ventures or partnerships, right to payment of commissions from a future event, firearms, deer stands, atv's, boats, trailers, and motors, documentation regarding hunting or fishing leases or rights or the rights to time share units or the use of property, tickets to events, like ballet or sporting events, proof of spa or club memberships, royalties from copyrights and patents, royalties from oil and gas ventures whether in the jurisdiction of the court and whether present or future, all property secreted by the debtor, all liens to secure performance, and income tax refunds in the debtor's name or to the debtor's account whether in trust or by direct deposit and to further provide the receiver with an accounting every month until the judgment is paid. This property cannot readily be attached or levied on by ordinary legal process. This property is not exempt under any statute from attachment, execution, or seizure for the satisfaction of liabilities. See Exhibit "A'attached hereto and incorporated herein by reference. 4. Receiver. Plaintiff requests the Court appoint Paul R. Wilson, whose address is 323 West Cano Street, Second Floor, Edinburg, Texas 78539 (telephone number (956) 316-0545; fax number (956) 316-0747) as receiver. 5. Attorney's Fees. Pluntiff is entitled to recover reasonable attorney's fees and costs. Reasonable fees for the attorney's services rendered and to be rendered arc at least $1,000.00. 6. Prayer. Plaintiff prays that the Court: a. set this matter for hearing; Electronically Submitted 6/10/2019 12:31 PM Hidalgo County Clerk Accepted by: Aurelio Aleman b. appoint Paul R. Wilson as receiver; b. issue the orders requested in this application; c. grant Plaintiff at least $1,000.00 as reasonable attorney's fees; d. grant Plaintiff reasonable expenses incurred in obtaining these orders; and e. grant all further relief to which Plaintiff may be entitled. Re spectfully submitted, BARNETT & GARCIA, PLLC A Professional Limited Liability Company 3821 Juniper Trace, Suite 108 Austin, Texas 78738 TELEPHONE: (5 12) 266-8830 FACSIMILE: (5 12) 266-8803 MilAA Matias Eduardo Garcra State Bar No.24012675 matt@b arnettgarc i a. com Sean S.V. Homrig State Bar No.24062789 sean@bamettgarcia. com