Preview
Filed
10/17/2023 10:39 PM
CV-0073785-A Dwight D. Sullivan
County Clerk
NO. Galveston County, Texas
BANK OF AMERICA, N.A. § IN THE COUNTY COURT
Garnishor
vs.
JPMORGAN CHASE BANK, N.A. AT LAW NO.
Garnishee Galveston County - County Court at Law No. 1
§
JOE L RUDD GALVESTON COUNTY, TEXAS
§
Defendant(s)
Y¥4-12120
APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT
1. Parties, Plaintiff in Garnishment is BANK OF AMERICA, N.A., which may be served
through its undersigned counsel of record. Garnishee is MORGAN CHASE BANK, N.A., which may
be served by delivering the writ to its registered agent, C T CORPORATION SYSTEM, at its registered
office 1999 BRYAN ST., SUITE 900 DALLAS, TX 75201-3136.
2. Affidavit for Garnishment. In Cause No. CV-0073785 on the docket of this Court, styled
"BANK OF AMERICA, N.A. v. JOE L RUDD," the Plaintiff obtained a judgment against such
Defendant, JOE L RUDD (Social Security Number ***-**-2490), (hereinafter referred to as
"Defendant") on June 24, 2015 in the principal amount of $10,136.53, and for all costs of this suit.
Said judgment is valid and subsisting and remains unsatisfied. Defendant does not possess, within
affiant's knowledge, property in Texas subject to execution sufficient to satisfy said judgment. The
garnishment applied for is not sued out to injure either the Defendant or Garnishee. The Affiant has
reason to believe, and does believe, that the said Garnishee is indebted to the Defendant by reason of one
or more bank accounts, or has effects belonging to the Defendant. The Affiant further says he/she is
authorized to make this affidavit and Application and that he/she has read this affidavit and that the
statements contained in this affidavit are within his/her pe nal knowledge and are true and correct.
Shawn R. Redman
THE STATE OF TEXAS
COUNTY OF HARRIS
swo
pr
AO'N
ny TO4 AND SUBSCRIBED BEFORE ME by the said Shar
¢ above-styled and numbered cause, on this
to certify which
at day of
igess my hand and seal of office.
attorney of
BESSIE FRANKLIN HUERY
Notary ID #133751180
My Commission Expires A ZA AW
(OTARY PUBL STATE
AKL | AY
O AS
May 9, 2026
3. Request for Writ. Plaintiff asks that a Writ of Garnishment issue and be served upon the said
Garnishee.
Respec} ly Submitted,
~Shawn R. Redman (SBN: 24033112)**
Teri S. Mace (SBN: 12759480)*
Marlei E. Thames (SBN: 24125221)*
Jeffrey Hacker (SBN: 08667300)*
Derek A. Devine (SBN: 24131174)**
Couch Lambert, LLC
*Dallas Office:
4144 North Central Expressway, Ste. 1260
Dallas, Texas 75204
**Houston Office:
6200 Savoy, Ste. 800
Houston, Texas 77036
***Mailing Address:
3501 N. Causeway, Ste. 800
Metairie, LA 70002
(866) 282-3853
ervicetx@gulfsouthlegal.com
ATTORNEYS FOR PLAINTIFF
Pe
JUL 2 0 2015
as 5
NO. CV-00 73 785
§s IN THE COUNTY CIVIL COURT
BANK OF AMERICA, N.A.
§ Galveston County - County Court at Law No. 1
$ AT LAW
VS.
GALVESTON COU ITY. TE
JOELR
Our F 4-12120
DEFAULT AUD
BE RED AN he appearance day of the above captioned Defendant having passed. and came
ey, hie eh duly s ved with process. the said Defendant. as at all times heretofor
e.
the said Plaintit?, ts align
return
failed to appear or an, er this behall) bu wholly made default: wheretofore, the ciation with the officer's
A. of this Court ten (10) days exctusive of filing and of this day. th id
thereon, having been on fife with Ub Ch
Plainti{Vought to recover tts: ends shy CASIO of the premises ayainst the suid Defendant being jnedefaul. andl
it appearing to the Court that he cayse Nuidated and that the Defendant is duly indebted to Plainult
bs stim aad amount of S$t0.136.5 and Jor all custs of Court in
(under account number *
this behalf expended: and it is there: are
and D D.ly that 2 Plaintiff. BANK OF AMERICA, NA
ORDERED. ADIUDGED
st endant. J nthe stan and amount ofS 14,136.53
do have and recover judgment from and ag
unul paid; and
It is further ORDE t 1) that Plaintiff shall 4 such w d orders as shail become. in Plaintif?s
behalf, necessary to enforce the execution of this judgment, rt =cat finally disposes of all partics and claims
and is appealable.
SIGNED this FE aver Jerne 2 9 Oo
wes
15 JUN 8
aang!
GALVES!
yynEY
y
oe kipsne
he fe sat
CL
Ty VE YAS
APPROVED: JUL 2.0 208
COUCH, CONVILLE & BLITT, LLC
pee fy
S$
LL. 33112)
SHAWN KX. R
shawn.7 NAN bg fsouthlewal.c Q
JAME HULL (SBN: 19 Aan33
jim. bull A fsouthiegal,edm
6200 Sav tite 40
Houston, Texas 036
(713) 952-1700
(713) 952-8375 (Fascin
ATTORNEYS FOR TIFF
PLAINTIFF'S ADDRESS:
BANK OF AMERICA, N.A)
cfo COUCH, CONVILLE & BLITA
6200 Savoy, Suite 440
Houston, Texas 77036
DEFENDANT'S ADDRESS:
JOEL RUDD
2203 JACK JOHNSON BLVD
GALVESTON TX 77550-6902
©
Y4-12120
FILE
15 JUN 25 PH
Lage
GALVES
J
TEXAS
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Filed 10/17/2023 10:39 PM CV-0073785-A Dwight D. Sullivan County Clerk NO. Galveston County, Texas BANK OF AMERICA, N.A. § IN THE COUNTY COURT Garnishor vs. JPMORGAN CHASE BANK, N.A. AT LAW NO. Garnishee Galveston County - County Court at Law No. 1 § JOE L RUDD GALVESTON COUNTY, TEXAS § Defendant(s) Y¥4-12120 APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT 1. Parties, Plaintiff in Garnishment is BANK OF AMERICA, N.A., which may be served through its undersigned counsel of record. Garnishee is MORGAN CHASE BANK, N.A., which may be served by delivering the writ to its registered agent, C T CORPORATION SYSTEM, at its registered office 1999 BRYAN ST., SUITE 900 DALLAS, TX 75201-3136. 2. Affidavit for Garnishment. In Cause No. CV-0073785 on the docket of this Court, styled "BANK OF AMERICA, N.A. v. JOE L RUDD," the Plaintiff obtained a judgment against such Defendant, JOE L RUDD (Social Security Number ***-**-2490), (hereinafter referred to as "Defendant") on June 24, 2015 in the principal amount of $10,136.53, and for all costs of this suit. Said judgment is valid and subsisting and remains unsatisfied. Defendant does not possess, within affiant's knowledge, property in Texas subject to execution sufficient to satisfy said judgment. The garnishment applied for is not sued out to injure either the Defendant or Garnishee. The Affiant has reason to believe, and does believe, that the said Garnishee is indebted to the Defendant by reason of one or more bank accounts, or has effects belonging to the Defendant. The Affiant further says he/she is authorized to make this affidavit and Application and that he/she has read this affidavit and that the statements contained in this affidavit are within his/her pe nal knowledge and are true and correct. Shawn R. Redman THE STATE OF TEXAS COUNTY OF HARRIS swo pr AO'N ny TO4 AND SUBSCRIBED BEFORE ME by the said Shar ¢ above-styled and numbered cause, on this to certify which at day of igess my hand and seal of office. attorney of BESSIE FRANKLIN HUERY Notary ID #133751180 My Commission Expires A ZA AW (OTARY PUBL STATE AKL | AY O AS May 9, 2026 3. Request for Writ. Plaintiff asks that a Writ of Garnishment issue and be served upon the said Garnishee. Respec} ly Submitted, ~Shawn R. Redman (SBN: 24033112)** Teri S. Mace (SBN: 12759480)* Marlei E. Thames (SBN: 24125221)* Jeffrey Hacker (SBN: 08667300)* Derek A. Devine (SBN: 24131174)** Couch Lambert, LLC *Dallas Office: 4144 North Central Expressway, Ste. 1260 Dallas, Texas 75204 **Houston Office: 6200 Savoy, Ste. 800 Houston, Texas 77036 ***Mailing Address: 3501 N. Causeway, Ste. 800 Metairie, LA 70002 (866) 282-3853 ervicetx@gulfsouthlegal.com ATTORNEYS FOR PLAINTIFF Pe JUL 2 0 2015 as 5 NO. CV-00 73 785 §s IN THE COUNTY CIVIL COURT BANK OF AMERICA, N.A. § Galveston County - County Court at Law No. 1 $ AT LAW VS. GALVESTON COU ITY. TE JOELR Our F 4-12120 DEFAULT AUD BE RED AN he appearance day of the above captioned Defendant having passed. and came ey, hie eh duly s ved with process. the said Defendant. as at all times heretofor e. the said Plaintit?, ts align return failed to appear or an, er this behall) bu wholly made default: wheretofore, the ciation with the officer's A. of this Court ten (10) days exctusive of filing and of this day. th id thereon, having been on fife with Ub Ch Plainti{Vought to recover tts: ends shy CASIO of the premises ayainst the suid Defendant being jnedefaul. andl it appearing to the Court that he cayse Nuidated and that the Defendant is duly indebted to Plainult bs stim aad amount of S$t0.136.5 and Jor all custs of Court in (under account number * this behalf expended: and it is there: are and D D.ly that 2 Plaintiff. BANK OF AMERICA, NA ORDERED. ADIUDGED st endant. J nthe stan and amount ofS 14,136.53 do have and recover judgment from and ag unul paid; and It is further ORDE t 1) that Plaintiff shall 4 such w d orders as shail become. in Plaintif?s behalf, necessary to enforce the execution of this judgment, rt =cat finally disposes of all partics and claims and is appealable. SIGNED this FE aver Jerne 2 9 Oo wes 15 JUN 8 aang! GALVES! yynEY y oe kipsne he fe sat CL Ty VE YAS APPROVED: JUL 2.0 208 COUCH, CONVILLE & BLITT, LLC pee fy S$ LL. 33112) SHAWN KX. R shawn.7 NAN bg fsouthlewal.c Q JAME HULL (SBN: 19 Aan33 jim. bull A fsouthiegal,edm 6200 Sav tite 40 Houston, Texas 036 (713) 952-1700 (713) 952-8375 (Fascin ATTORNEYS FOR TIFF PLAINTIFF'S ADDRESS: BANK OF AMERICA, N.A) cfo COUCH, CONVILLE & BLITA 6200 Savoy, Suite 440 Houston, Texas 77036 DEFENDANT'S ADDRESS: JOEL RUDD 2203 JACK JOHNSON BLVD GALVESTON TX 77550-6902 © Y4-12120 FILE 15 JUN 25 PH Lage GALVES J TEXAS