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2022-11334C / Court: 157
CAUSE NO. 2022-11334-C
SOUTH RIVER CAPITAL, LLC § IN THE DISTRICT COURT
Plaintiff/Judgment Creditor, §
Vs.
KENDRICK PERKINS 157th JUDICIAL DISTRICT
Defendant/Judgment Debtor,
vs.
JPMORGAN CHASE BANK, N.A.
Garnishee. HARRIS COUNTY, TEXAS
DECLARATION OF JOHN H. “JACK” MILLER, TT
I, as attorney for Judgment Creditor South River Capital, LLC (“South
River”), make this declaration under penalty of perjury as to the following facts
in support of South River’s application for writ of garnishment:
1 My name is John H, Miller, 1. I am more commonly known by my
nickname, “Jack.” 1am an attorney in good standing and licensed to practice law
in the state of Texas. My date of birth is December 2, 1986, and my work mailing
address is P.O. Box 8218, Houston, TX 77288. The following statements are
within my personal knowledge, from review of my files, communications with
my client South River Capital, LLC, and the records of the 157th Judicial District
Court or from personal investigation, to be true and correct.
2 On or about February 23, 2022, South River, through its counsel in
that matter Shawn Grady, filed a Petition to Enforce Foreign Judgment in the 157"
Judicial District Court of Harris County, Texas, domesticating in Texas a certain
DECLARATION OF JOHN H. “JACK” MILLER, IL. PAGE 1
rs
judgment rendered in Maryland on or about September 17, 2021, in favor of
Plaintiff South River Capital, LLC against Defendant Kendrick Perkins. The
Judgment entitled South River to recover $239,391.74 in damages, reasonable
and necessary attorneys’ fees in the amount of $35,908.76, pre-judgment interest
in the amount of $664.98 and plus costs and interest at the contractual rate of
20% from the date of judgment. In reviewing the law in Maryland, it appears the
maximum rate of interest permitted under Maryland law for loans greater than
$2,000.00 is 24%, so the 20% rate of interest is permitted under Maryland law.
3 Iam Judgment Creditor’s attorney and have been retained to collect
the remaining amounts owed on the Judgment in Texas as reported to me by
South River Capital, LLC.
4 Ihave attempted to locate property in the State of Texas that may be
owned by Defendant Kendrick Perkins. Property located at 7235 Royal Meadows
Blvd, Port Arthur, TX 77642 was struck off by Deed under Execution to South
River for $1,818.30. I reviewed a certain “Alias” Writ of Execution dated June 10,
2022, that indicates execution was returned nulla bonna. I also reviewed a certain
Agreed Judgment in Cause No. 2022-11344-B, indicating South River Capital, LLC
only was awarded $32,059.67 in such action. Defendant Kendrick Perkins also
owns 8522 Haven Trail, Tomball, TX 77375, although that property appears to
be his homestead and is therefore exempt from execution. To date, I have not
been able to locate other non-exempt assets in the State of Texas that might
suffice to fully satisfy the Judgment, which appears in all things to be final, valid,
subsisting, and not satisfied.
DECLARATION OF JOHN H. “JACK” MILLER, TID PAGE 2
rs
5 Therefore, within my knowledge and to the best of my knowledge,
Judgment Debtor does not possess property in Texas subject to execution
sufficient to satisfy the Judgment,
6. I have reason to believe JPMorgan Chase Bank, N.A. (Garnishee) is
indebted to or possessed non-exempt property belonging to Judgment Debtor.
Specifically, I reviewed a certain tweet made by Defendant Kendrick Perkins
dated February 11, 2022, in which he states he met the “Greatest Boxer of All
Time” while stopping to make a deposit at the bank. The tweet is snipped as
follows
Kendrick Perkins
@KendrickPerkins
Stopped by the bank to make a deposit and ran into the Greatest Boxer
Of All-Timell! Of course he was taking all the bank money && @& & Gotta
get my bankroll up! Carry the hell on 22 JG
£ fe
ey
ANS
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DECLARATION OF JOHNH. “JACK” MILLER, III PAGE 3
rs
The photo appears to have been taken at a bank lobby and depicts Defendant
Kendrick Perkins standing with a man wearing a hat bearing the initials “TMT.”
The man’s appearance matches that of boxer Floyd “Money” Mayweather. The
“TMT” logo matches that of “The Money Team,” a brand started by Floyd
Mayweather. An article dated September 4, 2013, by Tim Keown for ESPN about
Mr. Mayweather indicated he has only one bank account. Several more recent
social media posts indicate Mr. Mayweather was spotted at Chase Bank, including
a video featuring “TMT” representatives in 2017 at Times Square and a more
recent video featuring TMT trucks at Chase Bank following Mr. Mayweather’s
fight with Logan Paul in June 2021. In light of Mr. Mayweather’s apparent
preference to bank at Chase Bank, the article indicating he has only one bank
account, and the social media post from Mr. Perkins indicating he ran into Mr.
Mayweather at the bank, I therefore believe Kendrick Perkins has a bank account
with JPMorgan Chase Bank, N.A.
Executed in Harris County, Texas on ene Za 23,
Johf
_te
H4ack” Miller, I, Attorney for
Jud: ent Creditor South River Capital,
LLC
DECLARATION OF JOHN H. “JACK” MILLER, TD PAGE 4
rs
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2022-11334C / Court: 157 CAUSE NO. 2022-11334-C SOUTH RIVER CAPITAL, LLC § IN THE DISTRICT COURT Plaintiff/Judgment Creditor, § Vs. KENDRICK PERKINS 157th JUDICIAL DISTRICT Defendant/Judgment Debtor, vs. JPMORGAN CHASE BANK, N.A. Garnishee. HARRIS COUNTY, TEXAS DECLARATION OF JOHN H. “JACK” MILLER, TT I, as attorney for Judgment Creditor South River Capital, LLC (“South River”), make this declaration under penalty of perjury as to the following facts in support of South River’s application for writ of garnishment: 1 My name is John H, Miller, 1. I am more commonly known by my nickname, “Jack.” 1am an attorney in good standing and licensed to practice law in the state of Texas. My date of birth is December 2, 1986, and my work mailing address is P.O. Box 8218, Houston, TX 77288. The following statements are within my personal knowledge, from review of my files, communications with my client South River Capital, LLC, and the records of the 157th Judicial District Court or from personal investigation, to be true and correct. 2 On or about February 23, 2022, South River, through its counsel in that matter Shawn Grady, filed a Petition to Enforce Foreign Judgment in the 157" Judicial District Court of Harris County, Texas, domesticating in Texas a certain DECLARATION OF JOHN H. “JACK” MILLER, IL. PAGE 1 rs judgment rendered in Maryland on or about September 17, 2021, in favor of Plaintiff South River Capital, LLC against Defendant Kendrick Perkins. The Judgment entitled South River to recover $239,391.74 in damages, reasonable and necessary attorneys’ fees in the amount of $35,908.76, pre-judgment interest in the amount of $664.98 and plus costs and interest at the contractual rate of 20% from the date of judgment. In reviewing the law in Maryland, it appears the maximum rate of interest permitted under Maryland law for loans greater than $2,000.00 is 24%, so the 20% rate of interest is permitted under Maryland law. 3 Iam Judgment Creditor’s attorney and have been retained to collect the remaining amounts owed on the Judgment in Texas as reported to me by South River Capital, LLC. 4 Ihave attempted to locate property in the State of Texas that may be owned by Defendant Kendrick Perkins. Property located at 7235 Royal Meadows Blvd, Port Arthur, TX 77642 was struck off by Deed under Execution to South River for $1,818.30. I reviewed a certain “Alias” Writ of Execution dated June 10, 2022, that indicates execution was returned nulla bonna. I also reviewed a certain Agreed Judgment in Cause No. 2022-11344-B, indicating South River Capital, LLC only was awarded $32,059.67 in such action. Defendant Kendrick Perkins also owns 8522 Haven Trail, Tomball, TX 77375, although that property appears to be his homestead and is therefore exempt from execution. To date, I have not been able to locate other non-exempt assets in the State of Texas that might suffice to fully satisfy the Judgment, which appears in all things to be final, valid, subsisting, and not satisfied. DECLARATION OF JOHN H. “JACK” MILLER, TID PAGE 2 rs 5 Therefore, within my knowledge and to the best of my knowledge, Judgment Debtor does not possess property in Texas subject to execution sufficient to satisfy the Judgment, 6. I have reason to believe JPMorgan Chase Bank, N.A. (Garnishee) is indebted to or possessed non-exempt property belonging to Judgment Debtor. Specifically, I reviewed a certain tweet made by Defendant Kendrick Perkins dated February 11, 2022, in which he states he met the “Greatest Boxer of All Time” while stopping to make a deposit at the bank. The tweet is snipped as follows Kendrick Perkins @KendrickPerkins Stopped by the bank to make a deposit and ran into the Greatest Boxer Of All-Timell! Of course he was taking all the bank money && @& & Gotta get my bankroll up! Carry the hell on 22 JG £ fe ey ANS . -SS = & iC . . NV \ - \S _ ~_ SG Cc- \ \ \ aS \\ ~~~ \~~ \S \N oe DECLARATION OF JOHNH. “JACK” MILLER, III PAGE 3 rs The photo appears to have been taken at a bank lobby and depicts Defendant Kendrick Perkins standing with a man wearing a hat bearing the initials “TMT.” The man’s appearance matches that of boxer Floyd “Money” Mayweather. The “TMT” logo matches that of “The Money Team,” a brand started by Floyd Mayweather. An article dated September 4, 2013, by Tim Keown for ESPN about Mr. Mayweather indicated he has only one bank account. Several more recent social media posts indicate Mr. Mayweather was spotted at Chase Bank, including a video featuring “TMT” representatives in 2017 at Times Square and a more recent video featuring TMT trucks at Chase Bank following Mr. Mayweather’s fight with Logan Paul in June 2021. In light of Mr. Mayweather’s apparent preference to bank at Chase Bank, the article indicating he has only one bank account, and the social media post from Mr. Perkins indicating he ran into Mr. Mayweather at the bank, I therefore believe Kendrick Perkins has a bank account with JPMorgan Chase Bank, N.A. Executed in Harris County, Texas on ene Za 23, Johf _te H4ack” Miller, I, Attorney for Jud: ent Creditor South River Capital, LLC DECLARATION OF JOHN H. “JACK” MILLER, TD PAGE 4 rs