Preview
23-CCV-074097 Electronically Filed
12/28/2023 11:40 AM
Fort Bend County - Court at Law 4 Laura Richard
County Clerk
Fort Bend County, Texas
CAUSE NO.
TROY CAPITAL LLC § IN THE COUNTY COURT
Plaintiff §
§
vs.
ANITA PUNJABI § AT LAW NUMBER FOUR
Defendant §
§
PNC BANK
Garnishee § FORT BEND COUNTY, TEXAS
PLAINTIFF’S APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT
TO THE HONORABLE JUDGE OF SAID COURT:
Plaintiff in Garnishment, TROY CAPITAL LLC whose address is 2660 S RAINBOW
BLVD., #D104 LAS VEGAS NV 89146, hereby makes this application for a writ of
garnishment and in support, states as follows:
1 Plaintiff, TROY CAPITAL LLC is the judgment creditor in this action.
2. Garnishee, PNC BANK is a financial institution conducting business in Texas that may be
served with process by serving its registered agent, C/O CORPORATION SERVICE
COMPANY at 211 E 7TH STREET, SUITE 620, AUSTIN, TX 78701, or wherever it may be
found.
3 Pursuant to Tex. R. Civ. P. 663a, Judgment Debtor ANITA PUNJABI with the social
security number of (last 4) ***-** {J may receive notice of this garnishment action at the last
known address as follows: C/O Mastriani Law Firm, Christopher M. Thornhill
PO BOX 460174, Houston, TX 77056 or wherever he/she may be found.
MJAPC: MJAPC 15934.001
4. On February 9, 2015, a judgment was obtained on Case No. 12-CCV-047728 in this Court.
Plaintiff requests the Court to take judcial notice of the judgment in its file a dn the judgement is
incorporated herein by reference.
5 The judgment calculation is as follows;
Judgment Principle Balance $12,155.38
Judgment Costs Awarded $ 303.06
Attorney’s Fees Rendered at Judgment $ 1500.00
Post Judgment Interest $ 5340.04
Writ of Garnishment Filing $ 365.00
Writ of Garnishment Service Fee $ 140.00
Total Payments before Garnishment $0.00
TOTAL DUE =$ 19,803.48
6. The Judgment is valid, subsisting and completely unsatisfied. To the best of Plaintiff's
knowledge, the Judgment Debtor does not possess property in the State of Texas subject to
execution that is sufficient to satisfy the Judgment. This garnishment is not sought to injure
Judgment Debtor or the Garnishee.
7. Plaintiff has reason to believe, and does believe, that Garnishee has property belonging to
Judgment Debtor, or is indebted to Judgment Debtor, as a result of a contractual banking
relationship between Garnishee and Judgment Debtor which may include funds on deposit in one
or more savings and/or checking accounts. Therefore, all accounts in the name of Judgment
Debtor with Garnishee are effects belonging to the Judgment Debtor in this matter.
8. Plaintiff is entitled to the issuance of a Writ of Garnishment on the grounds supported by and
stated in the Affidavit of Plaintiffs Representative attached to this Application as Exhibit B and
incorporated by reference herein as if copied verbatim.
MJAPC: MJAPC 15934.001
PRAYER
WHEREFORE, TROY CAPITAL LLC prays for the following relief:
a. A Writ of Garnishment be issued directed to Garnishee;
b. Plaintiff be granted judgment against the Garnishee for $19,803.48 as the amount of
Plaintiff's Judgment already rendered against Judgment Debtor, together with interest
and costs of suit in the original case and in this garnishment proceeding;
Post-judgment interest on the Judgment in this garnishment proceeding, at the rate
stated in the Judgment or if not stated, at the statutory rate from the date of Judgment
until paid; and
Plaintiff be granted all other and further relief to which Plaintiff may be justly
entitled.
Dated: we 2 7
Resp submitted,
MICHAEL J. ADAMS | SB#24038732
10004 WURZBACH ROAD#292
SAN ANTONIO, TEXAS 78230
Toll Free Tel (877) 223-5462
Toll Free Fax (877) 240-5467
MAIL@MJAPCLAW.COM
ATTORNEY FOR PLAINTIFF
MJAPC: MJAPC 15934.001
EXHIBIT A
MJAPC: MJAPC 15934.001
SS
Gectronically Filed
41/4/2014 10:17:41 AM
Dianne Wilson
County Clerk
Fort Bend County, Texas
CAUSE NO. 12-CCV-047728
"AL LLC IN THE COUNTY COURT
AT LAW NUMBER FOUR
ANITA PUNJ. FORT BEND COUNTY, TEXAS
Defendant(s)
[UD WEN?)
Aftera 's Motion Summary Judgment, the Court has considered the
pleadings,
the evidence and ar; 1s presen! hesing ned official cont om fs in i coms en
of the opinion that judgmeat lou
It is accordingly ORD) BD DGED,ind Beenaty Q that Plaintiff TROY CAPITAL
a recover from Defendant(s) iT} JABI, sack for
. $12155.38 as the balance duc on the cout
costs of court;
attomeys’ fees in the amountof 60; and
post judgment interest at the rate of five So te eigucal hoe oe
of judgment until paid.
It is accordingly ORDERED that shall ts of execut ion
and other process
xl
ssar
to enforce this y
judgment. Ail relief not denied, as this judgment is
nece
etios
appealable and finally disposes of all parties and all cl
SIGNED this the. day HN lu
pe 7 1K
cx
AAs
JUD EPRESID
Al
a.
2
CZ
MIC IS PC.
AY
By,
ADAMS SB# 24038732
3201 CHBRRY RIDGE, STE 5205
SAN ANTONIO, TEXAS 78230
NO crED
CO O15
ER)
‘Tol Pree Tel (877) 223-5462 | Toll Pree Pax (877) 240-5467
\damspc.com
ATTORNEY
FOR PLAINTIFF
County Clerk Fortd 0. Texas,
MJAPC 15934.001
EXHIBIT B
MJAPC: MJAPC 15934.001
CAUSE NO.
TROY CAPITAL LLC § IN THE COUNTY COURT
Plaintiff
VS. AT LAW NUMBER FOUR
ANITA PUNJABI
Judgment Defendant
PNC BANK
Garnishee § FORT BEND COUNTY, TEXAS
AFFIDAVIT IN SUPPORT OF APPLICATION
FOR WRIT OF GARNISHMENT
STATE OF TEXAS §
§
COUNTY OF BEXAR §
Before me, the undersigned authority, on this personally appeared, MICHAEL J. ADAMS, who being
personally known to me, stated under oath that the following information is within his/her personal knowledge and is
true and correct:
My name is MICHAEL J. ADAMS. I am over 18 years of age, of sound mind, and capable of making this
affidavit. The facts stated in this affidavit are within my personal knowledge and are true and correct:
I am an authorized representative of TROY CAPITAL LLC, the judgment creditor in this action, and I serve
as the custodian of the records of TROY CAPITAL LLC.
Plaintiff has a valid, subsisting judgment, which the Court awarded a principle balance of $12155.38. This
balance does not include costs, attorney’s fees or accruing interest. See Plaintiff;s Applicaton for Writ of
Garnishment After Judgment. Within my knowledge, a supersedeas bond has not been approved and filed to suspend
execution of this judgment.
An asset search was performed on 11/21/2023, using LEXIS ADVANCE PUBLIC RECORDS. The search
failed to yield sufficient non-exempt property to satify the judgment. Therefore, within my knowledge, the Defendant
does not possess property in Texas subject to exec fficient to satisfy the judgment. The garnishment is not
sought to injure Debtor or Garnishee.
I have reason to believe and do believe th has property belonging to Debtor or is indebted to
Debtor.
Affiant
NOV 2 2 2023 20
NOTARY PUBLIC, STATZ OF TEXAS
My Commissi: pires
MJAPC: 15934.001 NICHOLAS STEVEN
;ONZALEZ
=k Notary ID #133886188
My Commission Expires
of So August 1, 2026
Preview
23-CCV-074097 Electronically Filed 12/28/2023 11:40 AM Fort Bend County - Court at Law 4 Laura Richard County Clerk Fort Bend County, Texas CAUSE NO. TROY CAPITAL LLC § IN THE COUNTY COURT Plaintiff § § vs. ANITA PUNJABI § AT LAW NUMBER FOUR Defendant § § PNC BANK Garnishee § FORT BEND COUNTY, TEXAS PLAINTIFF’S APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT TO THE HONORABLE JUDGE OF SAID COURT: Plaintiff in Garnishment, TROY CAPITAL LLC whose address is 2660 S RAINBOW BLVD., #D104 LAS VEGAS NV 89146, hereby makes this application for a writ of garnishment and in support, states as follows: 1 Plaintiff, TROY CAPITAL LLC is the judgment creditor in this action. 2. Garnishee, PNC BANK is a financial institution conducting business in Texas that may be served with process by serving its registered agent, C/O CORPORATION SERVICE COMPANY at 211 E 7TH STREET, SUITE 620, AUSTIN, TX 78701, or wherever it may be found. 3 Pursuant to Tex. R. Civ. P. 663a, Judgment Debtor ANITA PUNJABI with the social security number of (last 4) ***-** {J may receive notice of this garnishment action at the last known address as follows: C/O Mastriani Law Firm, Christopher M. Thornhill PO BOX 460174, Houston, TX 77056 or wherever he/she may be found. MJAPC: MJAPC 15934.001 4. On February 9, 2015, a judgment was obtained on Case No. 12-CCV-047728 in this Court. Plaintiff requests the Court to take judcial notice of the judgment in its file a dn the judgement is incorporated herein by reference. 5 The judgment calculation is as follows; Judgment Principle Balance $12,155.38 Judgment Costs Awarded $ 303.06 Attorney’s Fees Rendered at Judgment $ 1500.00 Post Judgment Interest $ 5340.04 Writ of Garnishment Filing $ 365.00 Writ of Garnishment Service Fee $ 140.00 Total Payments before Garnishment $0.00 TOTAL DUE =$ 19,803.48 6. The Judgment is valid, subsisting and completely unsatisfied. To the best of Plaintiff's knowledge, the Judgment Debtor does not possess property in the State of Texas subject to execution that is sufficient to satisfy the Judgment. This garnishment is not sought to injure Judgment Debtor or the Garnishee. 7. Plaintiff has reason to believe, and does believe, that Garnishee has property belonging to Judgment Debtor, or is indebted to Judgment Debtor, as a result of a contractual banking relationship between Garnishee and Judgment Debtor which may include funds on deposit in one or more savings and/or checking accounts. Therefore, all accounts in the name of Judgment Debtor with Garnishee are effects belonging to the Judgment Debtor in this matter. 8. Plaintiff is entitled to the issuance of a Writ of Garnishment on the grounds supported by and stated in the Affidavit of Plaintiffs Representative attached to this Application as Exhibit B and incorporated by reference herein as if copied verbatim. MJAPC: MJAPC 15934.001 PRAYER WHEREFORE, TROY CAPITAL LLC prays for the following relief: a. A Writ of Garnishment be issued directed to Garnishee; b. Plaintiff be granted judgment against the Garnishee for $19,803.48 as the amount of Plaintiff's Judgment already rendered against Judgment Debtor, together with interest and costs of suit in the original case and in this garnishment proceeding; Post-judgment interest on the Judgment in this garnishment proceeding, at the rate stated in the Judgment or if not stated, at the statutory rate from the date of Judgment until paid; and Plaintiff be granted all other and further relief to which Plaintiff may be justly entitled. Dated: we 2 7 Resp submitted, MICHAEL J. ADAMS | SB#24038732 10004 WURZBACH ROAD#292 SAN ANTONIO, TEXAS 78230 Toll Free Tel (877) 223-5462 Toll Free Fax (877) 240-5467 MAIL@MJAPCLAW.COM ATTORNEY FOR PLAINTIFF MJAPC: MJAPC 15934.001 EXHIBIT A MJAPC: MJAPC 15934.001 SS Gectronically Filed 41/4/2014 10:17:41 AM Dianne Wilson County Clerk Fort Bend County, Texas CAUSE NO. 12-CCV-047728 "AL LLC IN THE COUNTY COURT AT LAW NUMBER FOUR ANITA PUNJ. FORT BEND COUNTY, TEXAS Defendant(s) [UD WEN?) Aftera 's Motion Summary Judgment, the Court has considered the pleadings, the evidence and ar; 1s presen! hesing ned official cont om fs in i coms en of the opinion that judgmeat lou It is accordingly ORD) BD DGED,ind Beenaty Q that Plaintiff TROY CAPITAL a recover from Defendant(s) iT} JABI, sack for . $12155.38 as the balance duc on the cout costs of court; attomeys’ fees in the amountof 60; and post judgment interest at the rate of five So te eigucal hoe oe of judgment until paid. It is accordingly ORDERED that shall ts of execut ion and other process xl ssar to enforce this y judgment. Ail relief not denied, as this judgment is nece etios appealable and finally disposes of all parties and all cl SIGNED this the. day HN lu pe 7 1K cx AAs JUD EPRESID Al a. 2 CZ MIC IS PC. AY By, ADAMS SB# 24038732 3201 CHBRRY RIDGE, STE 5205 SAN ANTONIO, TEXAS 78230 NO crED CO O15 ER) ‘Tol Pree Tel (877) 223-5462 | Toll Pree Pax (877) 240-5467 \damspc.com ATTORNEY FOR PLAINTIFF County Clerk Fortd 0. Texas, MJAPC 15934.001 EXHIBIT B MJAPC: MJAPC 15934.001 CAUSE NO. TROY CAPITAL LLC § IN THE COUNTY COURT Plaintiff VS. AT LAW NUMBER FOUR ANITA PUNJABI Judgment Defendant PNC BANK Garnishee § FORT BEND COUNTY, TEXAS AFFIDAVIT IN SUPPORT OF APPLICATION FOR WRIT OF GARNISHMENT STATE OF TEXAS § § COUNTY OF BEXAR § Before me, the undersigned authority, on this personally appeared, MICHAEL J. ADAMS, who being personally known to me, stated under oath that the following information is within his/her personal knowledge and is true and correct: My name is MICHAEL J. ADAMS. I am over 18 years of age, of sound mind, and capable of making this affidavit. The facts stated in this affidavit are within my personal knowledge and are true and correct: I am an authorized representative of TROY CAPITAL LLC, the judgment creditor in this action, and I serve as the custodian of the records of TROY CAPITAL LLC. Plaintiff has a valid, subsisting judgment, which the Court awarded a principle balance of $12155.38. This balance does not include costs, attorney’s fees or accruing interest. See Plaintiff;s Applicaton for Writ of Garnishment After Judgment. Within my knowledge, a supersedeas bond has not been approved and filed to suspend execution of this judgment. An asset search was performed on 11/21/2023, using LEXIS ADVANCE PUBLIC RECORDS. The search failed to yield sufficient non-exempt property to satify the judgment. Therefore, within my knowledge, the Defendant does not possess property in Texas subject to exec fficient to satisfy the judgment. The garnishment is not sought to injure Debtor or Garnishee. I have reason to believe and do believe th has property belonging to Debtor or is indebted to Debtor. Affiant NOV 2 2 2023 20 NOTARY PUBLIC, STATZ OF TEXAS My Commissi: pires MJAPC: 15934.001 NICHOLAS STEVEN ;ONZALEZ =k Notary ID #133886188 My Commission Expires of So August 1, 2026