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2/2/2024 2:09 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
DC-24-01723 Christi Underwood DEPUTY
CAUSE NO.
WELLS FARGO BANK, NA., IN THE DISTRICT COURT
Garnishor,
192ND
Vv. JUDICIAL DISTRICT
NEIGHBORHOOD CREDIT UNION,
Garnishee. DALLAS COUNTY, TEXAS
APPLICATION FOR WRIT OF GARNISHMENT
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, Garnishor Wells Fargo Bank, NA. (“Garnishor”, herein after) and makes
this Application for Writ of Garnishment against Garnishee Neighborhood Credit Union
(“Garnishee”, hereinafter) and, in support hereof, Garnishor would show the Court the following:
I
1 Plaintiff/Garnishor is Wells Fargo Bank, NA.
2 Defendant/Garnishee Neighborhood Credit Union may be served by serving its
registered agent, President, Vice President and/or Head Cashier, 13649 Montfort Dr, Dallas TX
75240.
3 Venue is appropriate in Dallas County, Texas because the Judgment (as defined
below) was rendered in Dallas County, Texas.
Il.
4 Garnishor obtained a Judgment on September 3, 2015 in a case styled Wells
Fargo Bank, NA. v. Katrina Whatley and Jeffrey A Whatley under Cause No. DC-14-03193, in
the 192ND Judicial District Court, Dallas County, Texas. The Judgment was awarded as
follows: the sum of $10,608.33 against Katrina Whatley and Jeffrey A Whatley (“Judgment”). A
true and correct copy of the Judgment is attached hereto as Exhibit “A” and incorporated herein
APPLICATION FOR WRIT OF GARNISHMENT PAGE 1
KATRINA WHATLEY
by reference for all purposes. The Judgment is entitled to credits in the amount of $7,550.00. As
of January 10, 2024, there is now still due on this Judgment in the amount of $3,058.33.
Til.
5 To the best of Garnishor’s knowledge, Katrina Whatley and Jeffrey A Whatley
(“Judgment Debtor”) does not possess property in Texas subject to execution that is sufficient to
satisfy the above-described claim.
Iv.
6 Garnishor has reason to believe, and does believe, that Garnishee may be indebted
to Judgment Debtor by maintaining or holding one or more bank accounts.
7
Garnishor believes Katrina Whatley’s social security number to be ***-**-4030
and addresses to be 316 E 6th St, Dallas Tx 75203.
8 Garnishor believes Jeffrey A Whatley’s social security number to be ***-**-4175
and addresses to be 316 E 6th St, Dallas Tx 75203.
9 Garnishor is not seeking to injure or harass the Garnishee or the Judgment Debtor
by sending out a Writ of Garnishment. Rather, Garnishor is attempting to collect on the
Judgment. Garnishor requests that if Garnishee is indebted to the Judgment Debtor, by any
account or otherwise, that Garnishee hold and allow Garnishor to garnish said belongings.
Garnishor also requests that if Garnishee holds possessions in a safety deposit box at any branch
that Garnishee hold and allow Garnishor to garnish said belongings as permitted by law.
Vv.
10. This Application is supported by the Affidavit of Thomas M. Sellers attached
hereto as Exhibit “B” and incorporated herein by reference for all purposes.
SE
APPLICATION FOR WRIT OF GARNISHMENT PAGE 2
KATRINA WHATLEY
WHEREFORE, PREMISES CONSIDERED, Garnishor Wells Fargo Bank, NA., requests
that a Writ of Garnishment be issued as above described and that Garnishor Wells Fargo Bank,
N.A. have judgment against Garnishee Neighborhood Credit Union to partially or totally satisfy
the claim above-mentioned as provided by law, together with all costs of Court incurred in this
proceeding, and other such relief to which Garnishor may be justly entitled.
Respectfully submitted,
WADDELL SERAFINO GEARY
RECHNER JENEVEIN, P.C.
1717 Main Street, 25™ Floor
Dallas, Texas 75201
Telephone: (214) 979-7442
Telecopier: (214) 979-7402
Thine
By
MARK RECHNER
State Bar No. 24058064
mrechner@wslawpc.com
THOMAS M. SELLERS
State Bar No. 24070589
tsellers@wslawpc.com
WHITNEY ABBOTT
wabbott@wslawpc.com
State Bar No. 24052628
STEPHEN MOZUR
State Bar No. 24105274
smozur@wslawpc.com
ATTORNEYS FOR GARNISHOR
a
APPLICATION FOR WRIT OF GARNISHMENT PAGE 3
KATRINA WHATLEY
EXHIBIT
CAUSE NO. DC-14-03193
WELLS FARGO BANK, NA, IN THE DISTRICT COURT
Plaintiff,
v. 192nd JUDICIAL DISTRICT
KATRINA WHATLEY,
Defendants, DALLAS COUNTY, TEXAS
AGREED JUDGMENT
pet
Came on to be heard the above-entitled and numbered cause wherein Wells Fargo Bank,
N.A. (“Wells Fargo”), is Plaintiff, and Katrina Whatley is the (“Defendant”),
WHEREAS, Defendant has agreed that judgment should be entered In favor of Wells
Fargo Bank, N.A. as follows:
IT IS ORDERED, ADJUDGED AND DECREED that Plaintiff Wells Fargo Bank, N.A.
have and recover from Defendant Katrina Whatley the sum of $10,608.33.
It is further ORDERED that Wells Fargo Bank, N.A. is awarded attorney’s fees in the
amount of $725.00 and all costs of court.
Siened his 3 dy or__S ) f 52015,
JUDGE TRENDING, Vl
|
AGREED JUDGMENT Pace |
Ketrina Whatley
AGREED AS TO FORM AND SUBSTANCE;
VINCENT LOPEZ SERAFINO & JENEVEIN, P.C.
1601 Elm Street, Suite 4100
gv
Dallas, Texas 75201
214/979-7400~Teleph
— one
214/979-7402— Fi mile
MARK Ri fale.
State Bai lo. 24058064
mrechne! wvitolaw, com
THOMAS M. SELLERS
State Bar No. 24070589
tsellers@vilolaw.com
Attorneys for Plaintiff,
WELUS FAR’ BANK, N.A.
a Whatley
Defgndant
AGREED AS TO FORM
BURT BARR & ASSOCIATES, L.L.P.
P.O. Box 223667
Dall Texas 75222-3667
Tel. (214)943-0012
Fax. (214)943-0048
M. Joseph Fogelman
M. JOSEPH FOGELMAN
Texas Bar No, 07206700
jfogelman@bbarr.com
Attorney for Defendant,
KATRINA WHATLEY
AGREED JUDGMENT PAGE 2.
Katrina Whatley
CAUSE NO.
WELLS FARGO BANK, NA., IN THE DISTRICT COURT
Garnishor,
Vv. JUDICIAL DISTRICT
NEIGHBORHOOD CREDIT UNION,
Garnishee. DALLAS COUNTY, TEXAS
AFFIDAVIT OF THOMAS M. SELLERS
STATE OF TEXAS §
COUNTY OF DALLAS §
BEFORE ME, the undersigned official, on this day, in the above entitled and numbered
cause, personally appeared before me, Thomas M. Sellers, who after being duly sworn, did
depose and state as follows:
1 “My name is Thomas M. Sellers. I am over 21 years of age, of sound mind, have
never been convicted of a felony and am capable of making this affidavit.
2 lam an attorney for Wells Fargo Bank, N.A., Garnishor in this Garnishment.
3 I have personal knowledge of the facts as stated in Garnishor Wells Fargo Bank,
N.A.’s (“Garnishor”) Application for Writ of Garnishment (“Application”) and they are true and
correct.
4 Defendant/Judgment Debtor Katrina Whatley and Jeffrey A Whatley (“Judgment
Debtor”) is indebted to Garnishor by way of a Judgment in the amount stated in Garnishor’s
Application and such sum is just, owing and unpaid.
5 It is my belief that, after running a real property search on Accurint, Judgment
Debtor does not possess property in this state on which a levy can be made sufficient to satisfy
AFFIDAVIT OF THOMAS M. SELLERS PAGE | OF 2
KATRINA WHATLEY
the outstanding just, owing and unpaid balance of the Judgment.
6. It is my belief that the property sought to be garnished in this action is not exempt
from garnishment.
7. The Writ of Garnishment is not sought for the purpose of harming Judgment
Debtor or Garnishee Neighborhood Credit Union.
Tu
THOMAS M. SELLERS
Subscribed and swom to before me on this {> day vpn. 2023.
J
lotary
ce pK
ublic, Infand For,
a>)
‘ate of Texas
Dallas/Texas
hyi M,
Ube YARELHI HERNANDEZ
otary Public, State of Texas}
2D) Comm. Expires 03-01-2027
Hn Notary 1D 13422970-7
FS
AFFIDAVIT OF THOMAS M. SELLERS PAGE 2 OF 2
KATRINA WHATLEY
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I 2/2/2024 2:09 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS DC-24-01723 Christi Underwood DEPUTY CAUSE NO. WELLS FARGO BANK, NA., IN THE DISTRICT COURT Garnishor, 192ND Vv. JUDICIAL DISTRICT NEIGHBORHOOD CREDIT UNION, Garnishee. DALLAS COUNTY, TEXAS APPLICATION FOR WRIT OF GARNISHMENT TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Garnishor Wells Fargo Bank, NA. (“Garnishor”, herein after) and makes this Application for Writ of Garnishment against Garnishee Neighborhood Credit Union (“Garnishee”, hereinafter) and, in support hereof, Garnishor would show the Court the following: I 1 Plaintiff/Garnishor is Wells Fargo Bank, NA. 2 Defendant/Garnishee Neighborhood Credit Union may be served by serving its registered agent, President, Vice President and/or Head Cashier, 13649 Montfort Dr, Dallas TX 75240. 3 Venue is appropriate in Dallas County, Texas because the Judgment (as defined below) was rendered in Dallas County, Texas. Il. 4 Garnishor obtained a Judgment on September 3, 2015 in a case styled Wells Fargo Bank, NA. v. Katrina Whatley and Jeffrey A Whatley under Cause No. DC-14-03193, in the 192ND Judicial District Court, Dallas County, Texas. The Judgment was awarded as follows: the sum of $10,608.33 against Katrina Whatley and Jeffrey A Whatley (“Judgment”). A true and correct copy of the Judgment is attached hereto as Exhibit “A” and incorporated herein APPLICATION FOR WRIT OF GARNISHMENT PAGE 1 KATRINA WHATLEY by reference for all purposes. The Judgment is entitled to credits in the amount of $7,550.00. As of January 10, 2024, there is now still due on this Judgment in the amount of $3,058.33. Til. 5 To the best of Garnishor’s knowledge, Katrina Whatley and Jeffrey A Whatley (“Judgment Debtor”) does not possess property in Texas subject to execution that is sufficient to satisfy the above-described claim. Iv. 6 Garnishor has reason to believe, and does believe, that Garnishee may be indebted to Judgment Debtor by maintaining or holding one or more bank accounts. 7 Garnishor believes Katrina Whatley’s social security number to be ***-**-4030 and addresses to be 316 E 6th St, Dallas Tx 75203. 8 Garnishor believes Jeffrey A Whatley’s social security number to be ***-**-4175 and addresses to be 316 E 6th St, Dallas Tx 75203. 9 Garnishor is not seeking to injure or harass the Garnishee or the Judgment Debtor by sending out a Writ of Garnishment. Rather, Garnishor is attempting to collect on the Judgment. Garnishor requests that if Garnishee is indebted to the Judgment Debtor, by any account or otherwise, that Garnishee hold and allow Garnishor to garnish said belongings. Garnishor also requests that if Garnishee holds possessions in a safety deposit box at any branch that Garnishee hold and allow Garnishor to garnish said belongings as permitted by law. Vv. 10. This Application is supported by the Affidavit of Thomas M. Sellers attached hereto as Exhibit “B” and incorporated herein by reference for all purposes. SE APPLICATION FOR WRIT OF GARNISHMENT PAGE 2 KATRINA WHATLEY WHEREFORE, PREMISES CONSIDERED, Garnishor Wells Fargo Bank, NA., requests that a Writ of Garnishment be issued as above described and that Garnishor Wells Fargo Bank, N.A. have judgment against Garnishee Neighborhood Credit Union to partially or totally satisfy the claim above-mentioned as provided by law, together with all costs of Court incurred in this proceeding, and other such relief to which Garnishor may be justly entitled. Respectfully submitted, WADDELL SERAFINO GEARY RECHNER JENEVEIN, P.C. 1717 Main Street, 25™ Floor Dallas, Texas 75201 Telephone: (214) 979-7442 Telecopier: (214) 979-7402 Thine By MARK RECHNER State Bar No. 24058064 mrechner@wslawpc.com THOMAS M. SELLERS State Bar No. 24070589 tsellers@wslawpc.com WHITNEY ABBOTT wabbott@wslawpc.com State Bar No. 24052628 STEPHEN MOZUR State Bar No. 24105274 smozur@wslawpc.com ATTORNEYS FOR GARNISHOR a APPLICATION FOR WRIT OF GARNISHMENT PAGE 3 KATRINA WHATLEY EXHIBIT CAUSE NO. DC-14-03193 WELLS FARGO BANK, NA, IN THE DISTRICT COURT Plaintiff, v. 192nd JUDICIAL DISTRICT KATRINA WHATLEY, Defendants, DALLAS COUNTY, TEXAS AGREED JUDGMENT pet Came on to be heard the above-entitled and numbered cause wherein Wells Fargo Bank, N.A. (“Wells Fargo”), is Plaintiff, and Katrina Whatley is the (“Defendant”), WHEREAS, Defendant has agreed that judgment should be entered In favor of Wells Fargo Bank, N.A. as follows: IT IS ORDERED, ADJUDGED AND DECREED that Plaintiff Wells Fargo Bank, N.A. have and recover from Defendant Katrina Whatley the sum of $10,608.33. It is further ORDERED that Wells Fargo Bank, N.A. is awarded attorney’s fees in the amount of $725.00 and all costs of court. Siened his 3 dy or__S ) f 52015, JUDGE TRENDING, Vl | AGREED JUDGMENT Pace | Ketrina Whatley AGREED AS TO FORM AND SUBSTANCE; VINCENT LOPEZ SERAFINO & JENEVEIN, P.C. 1601 Elm Street, Suite 4100 gv Dallas, Texas 75201 214/979-7400~Teleph — one 214/979-7402— Fi mile MARK Ri fale. State Bai lo. 24058064 mrechne! wvitolaw, com THOMAS M. SELLERS State Bar No. 24070589 tsellers@vilolaw.com Attorneys for Plaintiff, WELUS FAR’ BANK, N.A. a Whatley Defgndant AGREED AS TO FORM BURT BARR & ASSOCIATES, L.L.P. P.O. Box 223667 Dall Texas 75222-3667 Tel. (214)943-0012 Fax. (214)943-0048 M. Joseph Fogelman M. JOSEPH FOGELMAN Texas Bar No, 07206700 jfogelman@bbarr.com Attorney for Defendant, KATRINA WHATLEY AGREED JUDGMENT PAGE 2. Katrina Whatley CAUSE NO. WELLS FARGO BANK, NA., IN THE DISTRICT COURT Garnishor, Vv. JUDICIAL DISTRICT NEIGHBORHOOD CREDIT UNION, Garnishee. DALLAS COUNTY, TEXAS AFFIDAVIT OF THOMAS M. SELLERS STATE OF TEXAS § COUNTY OF DALLAS § BEFORE ME, the undersigned official, on this day, in the above entitled and numbered cause, personally appeared before me, Thomas M. Sellers, who after being duly sworn, did depose and state as follows: 1 “My name is Thomas M. Sellers. I am over 21 years of age, of sound mind, have never been convicted of a felony and am capable of making this affidavit. 2 lam an attorney for Wells Fargo Bank, N.A., Garnishor in this Garnishment. 3 I have personal knowledge of the facts as stated in Garnishor Wells Fargo Bank, N.A.’s (“Garnishor”) Application for Writ of Garnishment (“Application”) and they are true and correct. 4 Defendant/Judgment Debtor Katrina Whatley and Jeffrey A Whatley (“Judgment Debtor”) is indebted to Garnishor by way of a Judgment in the amount stated in Garnishor’s Application and such sum is just, owing and unpaid. 5 It is my belief that, after running a real property search on Accurint, Judgment Debtor does not possess property in this state on which a levy can be made sufficient to satisfy AFFIDAVIT OF THOMAS M. SELLERS PAGE | OF 2 KATRINA WHATLEY the outstanding just, owing and unpaid balance of the Judgment. 6. It is my belief that the property sought to be garnished in this action is not exempt from garnishment. 7. The Writ of Garnishment is not sought for the purpose of harming Judgment Debtor or Garnishee Neighborhood Credit Union. Tu THOMAS M. SELLERS Subscribed and swom to before me on this {> day vpn. 2023. J lotary ce pK ublic, Infand For, a>) ‘ate of Texas Dallas/Texas hyi M, Ube YARELHI HERNANDEZ otary Public, State of Texas} 2D) Comm. Expires 03-01-2027 Hn Notary 1D 13422970-7 FS AFFIDAVIT OF THOMAS M. SELLERS PAGE 2 OF 2 KATRINA WHATLEY