Preview
2022-11334C / Court: 157 2/23/2022 3:85 PM
Marilyn Burgess - District Clerk Harris Gounty
Envelope No. 62920979
2022-11334 / Court: 157 By: Cecilla Thayer
Filed: 2/23/2022 3119 PM
CAUSE NO.
SOUTH RIVER CAPITAL, LLC
Plaintiff
IN THE DISTRICT COURT OF
P\\
Neca
HARRIS COUNTY, TEXAS SE
KENDRICK PERKINS
Defendant.
8 JUDICIAL COURT
PETITION TO ENFORCE FOREIGN JUDGMENT
TO THE HONORABLE JUDGE OF SAID COURT:
/MES NOW, SOUTH RIVER CAPITAL, LLC, hereinafter referred to as Plaintiff, and
Uniform
files this petition for enforcement of a foreign judgment in accordance with the
and Remedies
Enforcement of Foreign Judgment Act, and Chapter 35 of the Texas Civil Practice
Code; against KENDRICK PERKINS, hereinafter referred to as Defendant.
KENDRICK PERKINS may be given notice of this proceeding by delivering at, 8522 Haven
Texas 77642, or 10960
Trail, Tomball, Texas 77375, or 7235 Royal Meadows Street, Port Arthur,
Wilshire Blvd. FI 5, Los Angeles CA 90024.
Heretofore, on September 17, 2021, in the Circuit Court, County of Baltimore, State of
.74,
Maryland, Plaintiff recovered a judgment against the Defendant in the principal sum of $239,391
plus attorney’s fees in the amount of $35,908.76, and pre-judgment interest of $664.98, and post-
ofthe
judgment interest at the contractual rate of 20% per annum until the judgment is paid. A copy
of |
judgment is attached hereto. The law of the State of Maryland was in effect atthe time of entry
judgment provided for post judgment interest as described above,
| RECORDER'S
TA This instrument is of poor
Ai tre oti
WHEREFORE, Plaintiff prays that the copy of the judgment be filed in accordance with the
41
- law and that said judgment be domesticated having the same force and effect as if rendered in this
State,
Respectfully submitted,
LAW FIRM oF SHAWN M. GRADY, PLLC
By: |-_/s/ Shawn M Grady
Shawn
M. Grady
SBN 24076411
collectionlaw.com
2100 West Loop South, Ste. 805
Houston, Texas 77027
Phone (832) 692-4542
Fax (832) 565-1796
EX
THE STATE OF TEXAS §
COUNTY OF HARRIS §
BEFORE ME, the undersigned authority, on this day did personally appear Shawn M.
Grady who being first duly swom, did say and depose:
1 He is the attorney for the Judgment-Creditor
in this State, and his address is 4714
Sanford Road, Houston, Texas, 77035.
‘The name of the Judgment-Creditor is SOUTH RIVER CAPITAL, LLC.
The last known addresses for the Judgment-Debtoris: Kendrick Perkins, 8522 Haven
Trail, Tomball, Texas 77375 and 7235 Royal Meadows Street, Port Arthur, Texas
71642, and 10960 Wilshire Boulevard, Fi. 5, Los Angeles, CA 90024.
The address of the Plaintiff is 1 Park Place, Suite 540, Annapolis, MD 21401.
tL
$I M. Grady
SUBSCRIBED AND SWORN TO, before me, the undersigned authority, on this 22nd
day of February, 2022.
.
NOTARY LIGINAND FOR STATE
OF TEXAS
NOTICE OF FILING, PROOF OF MAILING,
I hereby certify that this instrument has been filed with the Court and a true and correct
copy of the foregoing document has been forwarded to the following:
Kendrick Perkins CMRRR 7021 2726 6002 2230 6653
8522 Haven Trail
Tomball, Texas 77375
Kendrick Perkins CMRRR 7021 2726 6602 2236 0639
7235 Royal Meadows
Street
Port Arthur, Texas 77642
Kendrick Perkins CHRRR 7021 2726 0602 2230 0646
10960 Wilshire Blvd. Fi. 5
Los Angeles, California 90024
by certified mail, retumn receipt requested and US First Class Mail, this 22nd day of February,
2022.
XA
Shawn Gralty
‘The foregoing is true and correct and signed
under penalty of perjury
circuit cROABR
AG Bede Courk. MARFLAND
40} Bosley Avenue, P.O. Box 6754
EF fal Towson, MD 21285-6754
ey
Sees Main: 410-887-2601 Fox: 410-887-3062
Case Number: CAI-CV-21-003010
Other Reference Numbers:
SOUTH RIVER CAPITAL, LLC VS. KENDRICK PERKINS
Date: 12/23/2021
TRIPLE SEAL CERTIFICATION
STATE OF MARYLAND, BALTIMORE COUNTY:
THEREBY CERTIFY that the foreguing is a full, (rac aid correct copy of the following document in the ubove~
entitled case: ‘onfessed Judgment taken and cupied from the recond of procoedings in the above-referenced
IN TESTIMONY WHEREOF J hereto set my hand and affix
the sea} of the Circuii Court for Baltimore County on this
ae 12272
Julie L. Bs:
Sunde
£: Enspr
RRS Clerk of the it Court
Be
7
NAA
T, Ruth Ann Jakubowski, Presiding Judge of the Circuit Court for Baltimor:-County, Maryland, do hereby certify
that the foregoing attestation is in due.form and by she proper officer.
Given under my hand on this
Rath Ann Jakubow: 42921 94:53:55 AM
401 Bosicy Avenue,
Towson, MD 21285. 6754
Thereby certify that the Honorable Ruth Aun Jakubowski, whose signature is subscribed to the foregoing
certificate, was at the ime of signing the same Presiding Jadge of the Circuit Coyrt for Baltimore Cobmry, Maryland, duty:
commissioned and qualified.
IN TESTIMONY WHEREOF I bereio sei my hand and affix
the seal of the Circuit Court for Baltimore County on this
12702
Julie L. Ensor
nudes Lo Emap’.
Clerk of the Citeuit Court
CC-019 (Rev. 66/2015) Page tof 2 42re3f2021 10:58 AM
EX
Case Number: C-03-CV-21-003010
CC-002 (Rev. 0004 Dated. 01/29/2012) Page
2 f2 4212972024 10:59 A
CIRCUIT COURT FOR BALTIMORE COUNTY, Main: 410-887-2604
MARYLAND Fax: 41 -B87-3062
40) Bosley Avenue, P.O. Box 6754
Towson,MD 21285-6754
To: Kendrick L. Perkins
8522 Haven Trail
Tomball, TX 77375
Case Number: CAS-CV2IIOIG
SOUTH RIVER CAPITAL, LLC YS. KENDRICK PERKINS
Date: 12/16/2021
NOTICE OF CONFESSED JUDGMENT
THEREBY CERTIFY thai the following Judgment has been revarded in this Court in the above entitled case.
Judginent against: Kendrick L, Perkins y
8522 Haven Trail
Tomball TX 773IS
Sndginent in favor of: South River Capitai, LLC
| Park Place, Suite 540
Annapolis MD 21401
Judgment ordered on: 9717/2021 Other See: $0.00
Jadgrient entry date: O9/1372021 Service fee: $0.00
Avtount of judgment: $239,391.74 Attomey fee: $35908.76
Pre judgment inierest: $664.98
Appearance fee: $0.00 Total jadgment: $275,965.48
Filnig fee. 50.00 .
Comments: plas costs and inivrest ftom date of judgment at the contractual defaclt raic of 20%. per aru.
You have 30 days after service of this notice Upon you lo file a wrilten motion is open, modify or
vacate the judgment.
IN TESTIMONY, [hereunto get my bard and affix the seal of this court.
2 ko Enspr—
Jolie L, Ensor
Clerk of the Circuit Court
Notice
You may receive a Judgment Debtor (Defendant) Information Sheet (CC-DC-CV-114) from the
plnintiffor the plaintiff's attorney requesting information under oath about you, your employ yment, and your assets,
fiabilitics, income, and expenses, You do not have to complete and retam that forns, but if you fail to do eo withinthe Gime:
allowed, you maybe summoned to appear ur undergo an examination under oath before a judge or exartiner regarding
and return the completed Judgment Debtor (Defendant) Information Sheet within the
those matters. If you fully complete
time allowed, you will not be subject ta discovery in aid of enforcement for at least one year from the entry of the
judgment againsl you, unless the judgment creditor bas been granted leave of court or good cause shown,
|
CC-CV-034 (Rev. 08/2028) Page 1 0f3 A2AM2021 1102 AM,
South River Capital, LLC vs. Kendrick Perkias Case Number: C-03-CV-21-003010
CC-CV-034 (Rav. 08/2020) Page
2 of 3 07/83/2014 12:22 PAK
South River Capital, LLC vs. Keadrick Perkins Case Number: C-03-CV-21-003010
SHERIFF'S RETURN
Notice of Confessed Judgment
Cireuit Court for Baltimore County
South River Capital, LLC vs. Kendrick Perkins
To: Kendrick
L. Perkins
Sheriff fee: By:
Served:
Time:
Unserved (Reason):
Instructions
to Private Process:
L This summons is effective for service only if served 60 days after the date issued,
2, Proof of Service shall set out the name of the person served, dete and the particnlar place and manner of service.
If service is not made, please state the reasons.
3. Return of served or unserved process shall be made promptly.
CC-CV-034 (Rev. 08/2020) Paga
3 of 3 0703/2014 12:22 Pil
2/23/2022 B:16 PM
Marlyn Burgess - District Glock Hamif County
Envelope No. 62031072
By: LISA GOOPER
Filed: 2/23/2022 B:18 PM
CAUSE NO. 2022-11334
SOUTH RIVER CAPITAL, LLC IN THE DISTRICT COURT OF
Plaintiff
V. HARRIS COUNTY, TEXAS
KENDRICK PERKINS
Defendant.
§ 157th JUDICIAL COURT
NOTICE OF FILING FOREIGN JUDGMENT PURSUANT TO TEXAS CIVIL
PRACTICE AND REMEDIES CODE, CHAPTER 35
TO: KENDRICK PERKINS
PLEASE TAKE NOTICE that Plaintiff, SOUTH RIVER CAPITAL, LLC, filed for record
a judgment from the CIRCUIT COURT, County of BALTIMORE, State of MARYLAND,
providing for recovery against you in the following amounts:
Princij $239,391.74
Attomey’s Fees $ 35,908.76
Pre-judgment Interest $ 664.98
Post-judgment Interest (20% per annum as of 2/22/22) $ 20,594.25
TOTAL (as of 2/22/22) $ 296,559.73
You are being served with this Notice Pursuant to Chapter 35, Texas Civil Practice and
Remedies Code.
EAN
Respectfully submitted,
LAW FIRM OF SHAWN M. GRADY, PLLC
By: /s/ Shawn M. Grady
Shawn M. Grady
SBN 24076411
shawn@gradycollectionlaw.com
2100 West Loop South, Ste. 805
Houston, Texas 77027
Phone (832) 692-4542
Fax (832) 565-1 796
\
NOTI F FILING, PROOF OF G.
AND CERTIFICATE OF SER'
Thereby certify that this instrument has been filed with the Court and a true
and correct
copy of the foregoing document has been forwarded to the following:
Kendrick Perkins CMRRR 7021 2720 0002 2230 0653
8522 Haven Trail
Tomball, Texas 77375
Kendrick Perkins | CMRRR 7021 2720 0002 2230 0639
7235 Royal Meadows Street
Port Arthur, Texas 77642
Kendrick Perkins CMRRR 7021 2720 0002 2230 0646
10960 Wilshire Blvd. Fl. 5
Los Angeles, California 90024
by certified mail, return receipt requested and US First Class Mail, this 24th day of February,
2022.
~“e pr
The foregoing is true and correct and signed
under penalty
of perjury
A
Preview
2022-11334C / Court: 157 2/23/2022 3:85 PM Marilyn Burgess - District Clerk Harris Gounty Envelope No. 62920979 2022-11334 / Court: 157 By: Cecilla Thayer Filed: 2/23/2022 3119 PM CAUSE NO. SOUTH RIVER CAPITAL, LLC Plaintiff IN THE DISTRICT COURT OF P\\ Neca HARRIS COUNTY, TEXAS SE KENDRICK PERKINS Defendant. 8 JUDICIAL COURT PETITION TO ENFORCE FOREIGN JUDGMENT TO THE HONORABLE JUDGE OF SAID COURT: /MES NOW, SOUTH RIVER CAPITAL, LLC, hereinafter referred to as Plaintiff, and Uniform files this petition for enforcement of a foreign judgment in accordance with the and Remedies Enforcement of Foreign Judgment Act, and Chapter 35 of the Texas Civil Practice Code; against KENDRICK PERKINS, hereinafter referred to as Defendant. KENDRICK PERKINS may be given notice of this proceeding by delivering at, 8522 Haven Texas 77642, or 10960 Trail, Tomball, Texas 77375, or 7235 Royal Meadows Street, Port Arthur, Wilshire Blvd. FI 5, Los Angeles CA 90024. Heretofore, on September 17, 2021, in the Circuit Court, County of Baltimore, State of .74, Maryland, Plaintiff recovered a judgment against the Defendant in the principal sum of $239,391 plus attorney’s fees in the amount of $35,908.76, and pre-judgment interest of $664.98, and post- ofthe judgment interest at the contractual rate of 20% per annum until the judgment is paid. A copy of | judgment is attached hereto. The law of the State of Maryland was in effect atthe time of entry judgment provided for post judgment interest as described above, | RECORDER'S TA This instrument is of poor Ai tre oti WHEREFORE, Plaintiff prays that the copy of the judgment be filed in accordance with the 41 - law and that said judgment be domesticated having the same force and effect as if rendered in this State, Respectfully submitted, LAW FIRM oF SHAWN M. GRADY, PLLC By: |-_/s/ Shawn M Grady Shawn M. Grady SBN 24076411 collectionlaw.com 2100 West Loop South, Ste. 805 Houston, Texas 77027 Phone (832) 692-4542 Fax (832) 565-1796 EX THE STATE OF TEXAS § COUNTY OF HARRIS § BEFORE ME, the undersigned authority, on this day did personally appear Shawn M. Grady who being first duly swom, did say and depose: 1 He is the attorney for the Judgment-Creditor in this State, and his address is 4714 Sanford Road, Houston, Texas, 77035. ‘The name of the Judgment-Creditor is SOUTH RIVER CAPITAL, LLC. The last known addresses for the Judgment-Debtoris: Kendrick Perkins, 8522 Haven Trail, Tomball, Texas 77375 and 7235 Royal Meadows Street, Port Arthur, Texas 71642, and 10960 Wilshire Boulevard, Fi. 5, Los Angeles, CA 90024. The address of the Plaintiff is 1 Park Place, Suite 540, Annapolis, MD 21401. tL $I M. Grady SUBSCRIBED AND SWORN TO, before me, the undersigned authority, on this 22nd day of February, 2022. . NOTARY LIGINAND FOR STATE OF TEXAS NOTICE OF FILING, PROOF OF MAILING, I hereby certify that this instrument has been filed with the Court and a true and correct copy of the foregoing document has been forwarded to the following: Kendrick Perkins CMRRR 7021 2726 6002 2230 6653 8522 Haven Trail Tomball, Texas 77375 Kendrick Perkins CMRRR 7021 2726 6602 2236 0639 7235 Royal Meadows Street Port Arthur, Texas 77642 Kendrick Perkins CHRRR 7021 2726 0602 2230 0646 10960 Wilshire Blvd. Fi. 5 Los Angeles, California 90024 by certified mail, retumn receipt requested and US First Class Mail, this 22nd day of February, 2022. XA Shawn Gralty ‘The foregoing is true and correct and signed under penalty of perjury circuit cROABR AG Bede Courk. MARFLAND 40} Bosley Avenue, P.O. Box 6754 EF fal Towson, MD 21285-6754 ey Sees Main: 410-887-2601 Fox: 410-887-3062 Case Number: CAI-CV-21-003010 Other Reference Numbers: SOUTH RIVER CAPITAL, LLC VS. KENDRICK PERKINS Date: 12/23/2021 TRIPLE SEAL CERTIFICATION STATE OF MARYLAND, BALTIMORE COUNTY: THEREBY CERTIFY that the foreguing is a full, (rac aid correct copy of the following document in the ubove~ entitled case: ‘onfessed Judgment taken and cupied from the recond of procoedings in the above-referenced IN TESTIMONY WHEREOF J hereto set my hand and affix the sea} of the Circuii Court for Baltimore County on this ae 12272 Julie L. Bs: Sunde £: Enspr RRS Clerk of the it Court Be 7 NAA T, Ruth Ann Jakubowski, Presiding Judge of the Circuit Court for Baltimor:-County, Maryland, do hereby certify that the foregoing attestation is in due.form and by she proper officer. Given under my hand on this Rath Ann Jakubow: 42921 94:53:55 AM 401 Bosicy Avenue, Towson, MD 21285. 6754 Thereby certify that the Honorable Ruth Aun Jakubowski, whose signature is subscribed to the foregoing certificate, was at the ime of signing the same Presiding Jadge of the Circuit Coyrt for Baltimore Cobmry, Maryland, duty: commissioned and qualified. IN TESTIMONY WHEREOF I bereio sei my hand and affix the seal of the Circuit Court for Baltimore County on this 12702 Julie L. Ensor nudes Lo Emap’. Clerk of the Citeuit Court CC-019 (Rev. 66/2015) Page tof 2 42re3f2021 10:58 AM EX Case Number: C-03-CV-21-003010 CC-002 (Rev. 0004 Dated. 01/29/2012) Page 2 f2 4212972024 10:59 A CIRCUIT COURT FOR BALTIMORE COUNTY, Main: 410-887-2604 MARYLAND Fax: 41 -B87-3062 40) Bosley Avenue, P.O. Box 6754 Towson,MD 21285-6754 To: Kendrick L. Perkins 8522 Haven Trail Tomball, TX 77375 Case Number: CAS-CV2IIOIG SOUTH RIVER CAPITAL, LLC YS. KENDRICK PERKINS Date: 12/16/2021 NOTICE OF CONFESSED JUDGMENT THEREBY CERTIFY thai the following Judgment has been revarded in this Court in the above entitled case. Judginent against: Kendrick L, Perkins y 8522 Haven Trail Tomball TX 773IS Sndginent in favor of: South River Capitai, LLC | Park Place, Suite 540 Annapolis MD 21401 Judgment ordered on: 9717/2021 Other See: $0.00 Jadgrient entry date: O9/1372021 Service fee: $0.00 Avtount of judgment: $239,391.74 Attomey fee: $35908.76 Pre judgment inierest: $664.98 Appearance fee: $0.00 Total jadgment: $275,965.48 Filnig fee. 50.00 . Comments: plas costs and inivrest ftom date of judgment at the contractual defaclt raic of 20%. per aru. You have 30 days after service of this notice Upon you lo file a wrilten motion is open, modify or vacate the judgment. IN TESTIMONY, [hereunto get my bard and affix the seal of this court. 2 ko Enspr— Jolie L, Ensor Clerk of the Circuit Court Notice You may receive a Judgment Debtor (Defendant) Information Sheet (CC-DC-CV-114) from the plnintiffor the plaintiff's attorney requesting information under oath about you, your employ yment, and your assets, fiabilitics, income, and expenses, You do not have to complete and retam that forns, but if you fail to do eo withinthe Gime: allowed, you maybe summoned to appear ur undergo an examination under oath before a judge or exartiner regarding and return the completed Judgment Debtor (Defendant) Information Sheet within the those matters. If you fully complete time allowed, you will not be subject ta discovery in aid of enforcement for at least one year from the entry of the judgment againsl you, unless the judgment creditor bas been granted leave of court or good cause shown, | CC-CV-034 (Rev. 08/2028) Page 1 0f3 A2AM2021 1102 AM, South River Capital, LLC vs. Kendrick Perkias Case Number: C-03-CV-21-003010 CC-CV-034 (Rav. 08/2020) Page 2 of 3 07/83/2014 12:22 PAK South River Capital, LLC vs. Keadrick Perkins Case Number: C-03-CV-21-003010 SHERIFF'S RETURN Notice of Confessed Judgment Cireuit Court for Baltimore County South River Capital, LLC vs. Kendrick Perkins To: Kendrick L. Perkins Sheriff fee: By: Served: Time: Unserved (Reason): Instructions to Private Process: L This summons is effective for service only if served 60 days after the date issued, 2, Proof of Service shall set out the name of the person served, dete and the particnlar place and manner of service. If service is not made, please state the reasons. 3. Return of served or unserved process shall be made promptly. CC-CV-034 (Rev. 08/2020) Paga 3 of 3 0703/2014 12:22 Pil 2/23/2022 B:16 PM Marlyn Burgess - District Glock Hamif County Envelope No. 62031072 By: LISA GOOPER Filed: 2/23/2022 B:18 PM CAUSE NO. 2022-11334 SOUTH RIVER CAPITAL, LLC IN THE DISTRICT COURT OF Plaintiff V. HARRIS COUNTY, TEXAS KENDRICK PERKINS Defendant. § 157th JUDICIAL COURT NOTICE OF FILING FOREIGN JUDGMENT PURSUANT TO TEXAS CIVIL PRACTICE AND REMEDIES CODE, CHAPTER 35 TO: KENDRICK PERKINS PLEASE TAKE NOTICE that Plaintiff, SOUTH RIVER CAPITAL, LLC, filed for record a judgment from the CIRCUIT COURT, County of BALTIMORE, State of MARYLAND, providing for recovery against you in the following amounts: Princij $239,391.74 Attomey’s Fees $ 35,908.76 Pre-judgment Interest $ 664.98 Post-judgment Interest (20% per annum as of 2/22/22) $ 20,594.25 TOTAL (as of 2/22/22) $ 296,559.73 You are being served with this Notice Pursuant to Chapter 35, Texas Civil Practice and Remedies Code. EAN Respectfully submitted, LAW FIRM OF SHAWN M. GRADY, PLLC By: /s/ Shawn M. Grady Shawn M. Grady SBN 24076411 shawn@gradycollectionlaw.com 2100 West Loop South, Ste. 805 Houston, Texas 77027 Phone (832) 692-4542 Fax (832) 565-1 796 \ NOTI F FILING, PROOF OF G. AND CERTIFICATE OF SER' Thereby certify that this instrument has been filed with the Court and a true and correct copy of the foregoing document has been forwarded to the following: Kendrick Perkins CMRRR 7021 2720 0002 2230 0653 8522 Haven Trail Tomball, Texas 77375 Kendrick Perkins | CMRRR 7021 2720 0002 2230 0639 7235 Royal Meadows Street Port Arthur, Texas 77642 Kendrick Perkins CMRRR 7021 2720 0002 2230 0646 10960 Wilshire Blvd. Fl. 5 Los Angeles, California 90024 by certified mail, return receipt requested and US First Class Mail, this 24th day of February, 2022. ~“e pr The foregoing is true and correct and signed under penalty of perjury A