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3/13/2024 9:52 AM
Marilyn Burgess - District Clerk Harris County
Envelope No. 85496130
2024-16086
/ Court: 164 By: Wanda Chambers
Filed: 3/12/2024 4:32 PM
CAUSE NO.
INDIANA TITLE NETWORK COMPANY § IN THE DISTRICT COURT OF
Plaintiff/Judgment-Creditor,
Vv. HARRIS COUNTY, TEXAS
ROBERT EARL BRIGGS
Defendant/Judgment-Debtor.
§ JUDICIAL DISTRICT
PETITION TO ENFORCE FOREIGN JUDGMENT
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, INDIANA TITLE NETWORK COMPANY, hereinafter referred to as
Plaintiff/Judgment-Creditor, and files this petition for enforcement of a foreign judgment in
accordance with the Uniform Enforcement of Foreign Judgment Act, and Chapter 35 of the Texas
Civil Practice and Remedies Code; against ROBERT EARL BRIGGS, hereinafter referred to as
Defendant/Judgment-Debtor.
Robert Earl Briggs may be given notice of this proceeding by delivering at 2744 Briarhurst
Dr Apt 7, Houston, Texas 77057, or wherever he may be found.
Heretofore, on January 3, 2024, under Cause No. 45D01-2308-PL-521, in the Superior Court
of Lake County, Civil Division 1, of the State of Indiana, Plaintiff/Judgment Creditor recovered a
judgment against the Defendant/Judgment-Debtor, in the principal sum of $5,263.60, together with
attorney’s fees in the amount of $600.00, plus court costs in the amount of $239.54, for a total sum
of $6,103.14. An exemplified copy of the judgment is attached hereto as Exhibit A.
WHEREFORE, Plaintiff/Judgment-Creditor prays that the copy of the Judgment be filed in
accordance with the 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
shawn@gradycollectionlaw.com
2100 West Loop South, Ste. 805
Houston, Texas 77027
Phone (832) 692-4542
Fax (832) 565-1796
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 sworn, did say and depose:
1 He is the attorney for the Plaintiff/Judgment-Creditor in this State, and his address is
2100 West Loop South, Suite 805, Houston, Texas 77027.
The name of the Defendant/Judgment-Debtor is ROBERT EARL BRIGGS.
The last known addresses for the Judgment-Debtors are listed below:
ROBERT EARL BRIGGS
2744 Briarhurst Dr Apt 7
Houston, Texas 77057
The address of the Plaintiff/Judgment-Creditor is c/o Shawn Grady, 2100 West Loop
South, Ste. 805, Houston, Texas 77027.
__Srdon M Grady
SUBSCRIBED AND SWORN TO, before me, the undersigned authority, on this 29th
day of February, 2024.
NOTARY PUBLIC
NOTARY PUBLIC IN AND FOR THE STATE
Wa 132517089 OF TEXAS
Comm, Exp, 06-03-2024
NOTICE OF FILING, PROOF OF MAILING,
AND CERTIFICATE OF SERVICE
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:
ROBERT EARL BRIGGS
2744 Briarhurst Dr Apt 7
Houston, Texas 77057
CMRRR 9415 5118 9956 4849 6058 67
by certified mail, return receipt requested and US First Class Mail, this 12th day of March,
i
2024.
Shawh M. Grady
The foregoing is true and correct and signed
under penalty of perjury
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3/13/2024 9:52 AM Marilyn Burgess - District Clerk Harris County Envelope No. 85496130 2024-16086 / Court: 164 By: Wanda Chambers Filed: 3/12/2024 4:32 PM CAUSE NO. INDIANA TITLE NETWORK COMPANY § IN THE DISTRICT COURT OF Plaintiff/Judgment-Creditor, Vv. HARRIS COUNTY, TEXAS ROBERT EARL BRIGGS Defendant/Judgment-Debtor. § JUDICIAL DISTRICT PETITION TO ENFORCE FOREIGN JUDGMENT TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, INDIANA TITLE NETWORK COMPANY, hereinafter referred to as Plaintiff/Judgment-Creditor, and files this petition for enforcement of a foreign judgment in accordance with the Uniform Enforcement of Foreign Judgment Act, and Chapter 35 of the Texas Civil Practice and Remedies Code; against ROBERT EARL BRIGGS, hereinafter referred to as Defendant/Judgment-Debtor. Robert Earl Briggs may be given notice of this proceeding by delivering at 2744 Briarhurst Dr Apt 7, Houston, Texas 77057, or wherever he may be found. Heretofore, on January 3, 2024, under Cause No. 45D01-2308-PL-521, in the Superior Court of Lake County, Civil Division 1, of the State of Indiana, Plaintiff/Judgment Creditor recovered a judgment against the Defendant/Judgment-Debtor, in the principal sum of $5,263.60, together with attorney’s fees in the amount of $600.00, plus court costs in the amount of $239.54, for a total sum of $6,103.14. An exemplified copy of the judgment is attached hereto as Exhibit A. WHEREFORE, Plaintiff/Judgment-Creditor prays that the copy of the Judgment be filed in accordance with the 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 shawn@gradycollectionlaw.com 2100 West Loop South, Ste. 805 Houston, Texas 77027 Phone (832) 692-4542 Fax (832) 565-1796 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 sworn, did say and depose: 1 He is the attorney for the Plaintiff/Judgment-Creditor in this State, and his address is 2100 West Loop South, Suite 805, Houston, Texas 77027. The name of the Defendant/Judgment-Debtor is ROBERT EARL BRIGGS. The last known addresses for the Judgment-Debtors are listed below: ROBERT EARL BRIGGS 2744 Briarhurst Dr Apt 7 Houston, Texas 77057 The address of the Plaintiff/Judgment-Creditor is c/o Shawn Grady, 2100 West Loop South, Ste. 805, Houston, Texas 77027. __Srdon M Grady SUBSCRIBED AND SWORN TO, before me, the undersigned authority, on this 29th day of February, 2024. NOTARY PUBLIC NOTARY PUBLIC IN AND FOR THE STATE Wa 132517089 OF TEXAS Comm, Exp, 06-03-2024 NOTICE OF FILING, PROOF OF MAILING, AND CERTIFICATE OF SERVICE 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: ROBERT EARL BRIGGS 2744 Briarhurst Dr Apt 7 Houston, Texas 77057 CMRRR 9415 5118 9956 4849 6058 67 by certified mail, return receipt requested and US First Class Mail, this 12th day of March, i 2024. Shawh M. Grady The foregoing is true and correct and signed under penalty of perjury