Preview
NO. 14-02825-431
PFISTER, BORSERINE &
ASSOCIATES, P.L.L.C.
"Plaintiff" & "Garnishor"
IN THE DISTRICT COURT
vs. OF DENTON COUNTY, TEXAS
WELLS FARGO BANK N.A.
“"Garnishee Bank"
431ST JUDICIAL DISTRICT
vs.
KARLA KENNARD
“Defendant (s)".
AAMAAAAAAAAMAA AW
GARNISHMENT ACTION
GARNISHEE'S ORIGINAL ANSWER, ET. SEQ.
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, WELLS FARGO BANK N.A., Individually and F/K/A
WACHOVIA BANK N.A., a national association with offices in
Texas, f/k/a WELLS FARGO BANK TEXAS, N.A. and f/k/a WELLS FARGO
BANK (TEXAS), N.A. (all such National Associations being
collectively referred to as “WELLS FARGO BANK, N.A.”)
hereinafter sometimes called "Garnishee Bank," and in response
to the Writ(s) of Garnishment served upon it by PFISTER,
BORSERINE & ASSOCIATES, P.L.L.C. ("Plaintiff(s)" &
"Garnishor(s)"), relating to KARLA KENNARD (herein sometimes
referred to as “Defendant” or “Judgment Debtor”) files this,
it’s “GARNISKEE'S ORIGINAL ANSWER, AND MOTIONS TO QUASH SERVICE
AND WRITS OF GARNISHMENT” and would show as follows:I.
Indebtedness of Garnishee Bank to
KARLA_ KENNARD
at Time Writ was Served
From the time the Writ of Garnishment was served upon
Garnishee Bank until the time of verifying this Answer, the
Garnishee Bank had no deposits for or on the Account(s) of
Defendant (s)/Judgment Debtor(s), except for the following
Account(s), which may possibly include indebtedness to the
Defendant (s) /Judgment Debtor(s):
ACCOUNT NAME(S AMOUNT (S
1. KARLA C KENNARD $ 453.57
2. KARLA C KENNARD $ 3.22
3. KARLA C KENNARD $ 19.00
4. KARLA C KENNARD $ 2,380.65
5. KARLA C KENNARD $ 156.50
In addition, some of the funds in these accounts may be
exempt from the instant Writ, lien, or underlying Judgment by
way of (1) The Federal Railroad Retirement Board (S5CFR Part
831, 841); (2) Social Security Administration (20 CFR parts
404,416); (3) Department of Veterans Affairs (38 CFR Part 212)
and/or (4) applicable state laws and statutes. As such, the
possibility exists that one or more of these Accounts, or
parts of the monies therein, may be exempt.In addition, some of the funds in these accounts may be
provisional credits based upon deposited items that have not
yet cleared the drawer bank. As such, the possibility exists
that one or more of these provisional items may be returned
unpaid. If this happens, then the Garnishee Bank reserves the
right to amend its Answer to show the reduction for unpaid
items,
In addition there are no safety deposit boxes possessed
by the Garnishee Bank, potentially in the name of KARLA
KENNARD, to the best of the knowledge of the Garnishee Bank,
These are the only amounts for which Garnishee Bank may
have been indebted to KARLA KENNARD at the time the Writ of
Garnishment was served.
In addition, the Garnishee Bank expresses no opinion on
whether or not the claim(s) in question asserted by
Garnishor(s) reach these Account(s), only that there is a
good-faith question regarding the same and that said
Account(s) in these names exist and are being held pending
further Order of the Court.il.
Personal Effects of
KARLA KENNARD
in Possession of Garnishee or Third Persons
At the time this Writ of Garnishment was served upon
Garnishee Bank, and at the time of filing this Answer,
Garnishee Bank did not and does not have in its possession any
effects belonging to KARLA KENNARD, and Garnishee Bank had no
knowledge of any other person, firm or corporation who has in
its possession any effects belonging to KARLA KENNARD, other
than the amounts shown in Paragraph I above.
IIz.
Persons Indebted to
KARLA_KENNARD
Garnishee Bank has no knowledge of any other person, firm
or corporation who was or is indebted to KARLA KENNARD, other
than the amounts set out in Paragraph I above.
Iv.
Claim for Attorneys' Fees
Garnishee Bank would show that it has employed the law
firm of Pearson & Pearson, L.L.P. to represent it in this
garnishment proceeding and to file an Answer on behalf ofGarnishee Bank. Garnishee Bank is entitled to recover from
Garnishor all reasonable attorneys’ fees incurred by Garnishee
Bank in the preparation, presentation and prosecution of this
Answer. A reasonable amount for such legal services at this
time is $ 500.
If the Debtor or any other Party or Intervener
controverts or disputes this Answer, then Garnishee Bank
requests additional Attorney’s Fees from the appropriate party
in the amount of $500 per hour.
Vv.
Unsworn) General Denial
To the extent that the foregoing Answer is in any way
insufficient for any reason, then the Garnishee Bank generally
denies each and every, all and singular, of the allegations set
forth in the Plaintiff's pleadings, as allowed by the Rules of
Civil Procedure. This general denial does not require
verification and the attached verification is not intended to
swear to this paragraph.vi.
Affirmative Defenses
Garnishee Bank pleads all of the affirmative defenses
under Tex. Rule Civ. Procedure 94, including the following:
i. Garnishee Bank would show that with regard to any loan(s)
or obligations due from the Owners/Signators on the
Garnished Accounts, the Garnishee Bank reserves its
rights of setoff or offset under common law, statutory
law, and the documents signed by the parties to the
Account (s)7
2. Any failure to give the Judgment Debtor Notice of this
proceeding and a chance to object under Texas Rules of
Civil Procedure 93(4) and 663a;
3. Any irregularities in the Application, Affidavit, any
Bond and the Writ itself under Rule 663a and 679. Strict
compliance is required;
4. Any irregularities in the time, method or manner of
service under T.R.C.P. 662 and 663 (see also Motion to
Quash below). Only Sheriffs and Constables may serve
Writs and that service must be upon the designated agent
for service of process;
5. Any misnomer of the Garnishee Bank or failure to properly
name the Garnishee Bank, other than “Wells Fargo Bank,
N.A.”;6. The rights of the Garnishee Bank under Texas Business &
Commerce Code Ann. see. 4.303(a),(b), and footnotes
thereto;
7. Any choice of-law-issues, conflicts, or applications.
Plaintiffs and Judgment Debtors reside in, and possess
accounts in, many different states;
8. Any misnomers, conflicts, or variations between (a) the
legal name of the Defendant, (b) the name of the Judgment
Debtor/Defendant (i) in the Final Judgment, (ii) in the
Application for Garnishment, and (iii) in the Writs of
Garnishment, and (c) the names on the Garnished Accounts
in question; and
9. Any grounds set out in the “Motions to Quash Service and
Writ(s) of Garnishment” set out below.
VII.
Motions to Quash Service and Writ(s) of Garnishment
A. Texas Finance Code.
The first ground of this Motion to Quash is that the
Texas Finance Code sets out the exclusive method of perfecting
service of a writ of garnishment upon a bank or financial
institution.In no case shall judgment be rendered against any
defendant unless upon service, or acceptance or waiver of
process, as prescribed by these rules, except where otherwise
expressly provided by law .. T.R.C.P. 124 (emphasis added).
Section 63.008 of the Texas Civil Practice and Remedies
Code controls the service of all Writs of Garnishment,
including the one in issue. That section incorporates sec.
59.008, Texas Finance Code. See, Tex. Civil Prac. & Rem. Code
Ann. Sec. 63.008.
Section 59.008 of the Texas Finance Code Annotated
states, “(a) claim against a customer of a financial
institution shall be delivered .. at the address designated as
the address of the registered agent .. in a registration filed
with the secretary of state pursuant to Section 201. ..” Tex.
Fin. Code Ann. Sec. 59.008 (Supp. 2003).
Section 201.102 and 201.103 relate to the appointment of
Yan agent authorized to receive service of process.” Tex. Fin.
Code Ann. Sec. 201.103 (Supp. 2003). Garnishee Bank, in good
faith, believes that it has complied with this section and
appointed an agent for service of process by filing with the
Texas Secretary of State, document #8832 on June 21, 2001,
designating Corporation Service Company d/b/a “CSC” in Austin,
Texas as its exclusive agent for service of process.Under Tex. Fin. Code sec. 59,008(c), the Judgment-Debtor
(i.e. original Defendant) “bears the burden of preventing or
limiting (the Garnishee Bank’s) compliance with or response to
a claim subject to this section by seeking an appropriate
remedy, including (T.R.O.), injunction, protective order, or
other remedy ..” Therefore, Garnishee Bank is giving the
Plaintiff notice of any deficiencies that exist in its service
(and opportunity to cure) and the Judgment-Debtor time to seek
appropriate remedies should he/she/they so choose.
B. Irregularities in Service.
Texas Rules of Civil Procedure 662 and 663 require
service by a Sheriff or Constable, upon the Garnishee Bank's
designated agent. Private process servers are prohibited.
Strict compliance with these Rules is required. Garnishee Bank
relies upon these Rules and any other irregularities in service
that may exist as grounds for this Motion.
Cc. Other Irregularities.
Garnishee Bank further relies upon the grounds set out
under VII entitled “Affirmative Defenses” and incorporates the
allegations set out therein as if repeated verbatim as further
grounds to quash the service as well as the Writ.WHEREFORE, PREMISES CONSIDERED, Garnishee Bank, WELLS
FARGO BANK N.A., prays that the writ and service be quashed,
the Judgment-Debtor be given notice of this action, that all
issues be joined, that upon final hearing this Court discharge
Garnishee Bank upon its Answer, that the Court enter other
appropriate Orders fully protecting Garnishee Bank, that all
costs be taxed against Garnishor, that Garnishee Bank be
awarded reasonable attorneys' fees, and that Garnishee Bank be
granted such other relief, legal or equitable, general or
special, to which it may show itself justly entitled.
Respectfully submitted,
PEARSON, PEARSON,
A Limited Liabilit rtnership
By:
PEARSON
ta Bar No. 15691200
29 Weslayan St., Ste. 580
Hotton, Texas 77027-5132
13) 739-8600 TELE
(713) 739-8341 FAX
Pearsonpc@aol.com EMAIL
ATTORNEYS FOR
WELLS FARGO BANK N.A.TATAM re eos Yo. 0861 Po dpe.
28148 From: : To! 18666721561 Pitre
VERIFTCAtTON
TAR STATE or ARTAQNA 8
“ §
COUNTY OF MARICOPA §
BEFORE ME, the undersigned authority, on this day
personally appeared the undersigned Person,.who first being
duly sworn on his/her oath, stated and deposed ag follows:
I am the one of the Custodians of the
Records for WELLS FARGO BANK NVA. I am S
‘ over the age af eighteen, am competent ° .
: te make this Affidavil, and fully
authorized to make this Affidavit on
behalt of weirs FARGO BANK N.A,
I have sosd the Original answer to the
Writ of Garnishment, havo Personal
knowledge of the factual matter st
out theyelu (based “pon a review at the
Records of the Bank), and they are true
aud correct, Whis verification doug not
Opply to Fars. iy and Following,
FURTHER AFFTAND SAvuTR Nor,
SWORN 4O AND —— day ot
hand and
My Commission Expires: —__]
nae Ree ener ne AAS
F SARSON | . t =95%:
MAY-32-2014 10:09AM From: TD: PEARSON Pasei@li R=95:CERTIFICATE OF SERVICE
I do hereby certify that June 2 2014 a true and correct
copy of the foregoing has been served upon PFISTER,
BORSERINE & ASSOCIATES, P.L.L.C., by serving a copy upon
his/her/their/its Attorney-of-record by facsimile -- return
receipt requested; email (where requested) ; U.S. Mail
postage pre-paid.
:\WPD\937000\025\ PLEAD\ORIG ANS:
PFISTER, BORSERINE & ASSOCIATES, P.L.L.C.
vs.
KARLA KENNARD
June 2, 2014
Garnishees Original AnswerPearson & Pearson, L.L.P.
ATTORNEYS AT LAW
TELEPHONE (713) 739-8600 2900 Weslayan Street, Suite 580 E-MAIL: Pearsonpe@aol.com
TELECOPIER (713) 739-8341 Houston, Texas 77027-5132
June 2, 2014
The Sherri Adelstein
District Clerk - DENTON County
County Courts Building, 1450 East McKinney Street, Suite 1200
P.O. Box 2146
Denton, Texas 76202-2146
Re: — Case No: 14-02825-431; 431ST JUDICIAL DISTRICT.
PFISTER, BORSERINE & ASSOCIATES, P.L.L.C. v. KARLA KENNARD, et. al.
Dear Clerk:
We represent the Defendant, WELLS FARGO BANK N.A. in the above entitled and
numbered cause of action.
1, With regard to this case, enclosed please find the Garnishee's Original Answer.
2. With regard to this and all other cases, please consider this our Notice of Change of
Address for our law firm and all Attorneys.
3. Opposing counsel is being notified of the filing of the same, as shown below.
4. Please return the enclosed copy, file stamped, for our files.
Yours truly,
By:
James H. Pearson
Ences.
CC. MR. JOHN J. PFISTER, JR.
CC. MS. JULIE HEWITT - WELLS FAR
‘QAWPD19370001025\COR\ORIG.ANS
Fax (972) 712-9205
Fax (866) 670-1561
Preview
NO. 14-02825-431 PFISTER, BORSERINE & ASSOCIATES, P.L.L.C. "Plaintiff" & "Garnishor" IN THE DISTRICT COURT vs. OF DENTON COUNTY, TEXAS WELLS FARGO BANK N.A. “"Garnishee Bank" 431ST JUDICIAL DISTRICT vs. KARLA KENNARD “Defendant (s)". AAMAAAAAAAAMAA AW GARNISHMENT ACTION GARNISHEE'S ORIGINAL ANSWER, ET. SEQ. TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, WELLS FARGO BANK N.A., Individually and F/K/A WACHOVIA BANK N.A., a national association with offices in Texas, f/k/a WELLS FARGO BANK TEXAS, N.A. and f/k/a WELLS FARGO BANK (TEXAS), N.A. (all such National Associations being collectively referred to as “WELLS FARGO BANK, N.A.”) hereinafter sometimes called "Garnishee Bank," and in response to the Writ(s) of Garnishment served upon it by PFISTER, BORSERINE & ASSOCIATES, P.L.L.C. ("Plaintiff(s)" & "Garnishor(s)"), relating to KARLA KENNARD (herein sometimes referred to as “Defendant” or “Judgment Debtor”) files this, it’s “GARNISKEE'S ORIGINAL ANSWER, AND MOTIONS TO QUASH SERVICE AND WRITS OF GARNISHMENT” and would show as follows:I. Indebtedness of Garnishee Bank to KARLA_ KENNARD at Time Writ was Served From the time the Writ of Garnishment was served upon Garnishee Bank until the time of verifying this Answer, the Garnishee Bank had no deposits for or on the Account(s) of Defendant (s)/Judgment Debtor(s), except for the following Account(s), which may possibly include indebtedness to the Defendant (s) /Judgment Debtor(s): ACCOUNT NAME(S AMOUNT (S 1. KARLA C KENNARD $ 453.57 2. KARLA C KENNARD $ 3.22 3. KARLA C KENNARD $ 19.00 4. KARLA C KENNARD $ 2,380.65 5. KARLA C KENNARD $ 156.50 In addition, some of the funds in these accounts may be exempt from the instant Writ, lien, or underlying Judgment by way of (1) The Federal Railroad Retirement Board (S5CFR Part 831, 841); (2) Social Security Administration (20 CFR parts 404,416); (3) Department of Veterans Affairs (38 CFR Part 212) and/or (4) applicable state laws and statutes. As such, the possibility exists that one or more of these Accounts, or parts of the monies therein, may be exempt.In addition, some of the funds in these accounts may be provisional credits based upon deposited items that have not yet cleared the drawer bank. As such, the possibility exists that one or more of these provisional items may be returned unpaid. If this happens, then the Garnishee Bank reserves the right to amend its Answer to show the reduction for unpaid items, In addition there are no safety deposit boxes possessed by the Garnishee Bank, potentially in the name of KARLA KENNARD, to the best of the knowledge of the Garnishee Bank, These are the only amounts for which Garnishee Bank may have been indebted to KARLA KENNARD at the time the Writ of Garnishment was served. In addition, the Garnishee Bank expresses no opinion on whether or not the claim(s) in question asserted by Garnishor(s) reach these Account(s), only that there is a good-faith question regarding the same and that said Account(s) in these names exist and are being held pending further Order of the Court.il. Personal Effects of KARLA KENNARD in Possession of Garnishee or Third Persons At the time this Writ of Garnishment was served upon Garnishee Bank, and at the time of filing this Answer, Garnishee Bank did not and does not have in its possession any effects belonging to KARLA KENNARD, and Garnishee Bank had no knowledge of any other person, firm or corporation who has in its possession any effects belonging to KARLA KENNARD, other than the amounts shown in Paragraph I above. IIz. Persons Indebted to KARLA_KENNARD Garnishee Bank has no knowledge of any other person, firm or corporation who was or is indebted to KARLA KENNARD, other than the amounts set out in Paragraph I above. Iv. Claim for Attorneys' Fees Garnishee Bank would show that it has employed the law firm of Pearson & Pearson, L.L.P. to represent it in this garnishment proceeding and to file an Answer on behalf ofGarnishee Bank. Garnishee Bank is entitled to recover from Garnishor all reasonable attorneys’ fees incurred by Garnishee Bank in the preparation, presentation and prosecution of this Answer. A reasonable amount for such legal services at this time is $ 500. If the Debtor or any other Party or Intervener controverts or disputes this Answer, then Garnishee Bank requests additional Attorney’s Fees from the appropriate party in the amount of $500 per hour. Vv. Unsworn) General Denial To the extent that the foregoing Answer is in any way insufficient for any reason, then the Garnishee Bank generally denies each and every, all and singular, of the allegations set forth in the Plaintiff's pleadings, as allowed by the Rules of Civil Procedure. This general denial does not require verification and the attached verification is not intended to swear to this paragraph.vi. Affirmative Defenses Garnishee Bank pleads all of the affirmative defenses under Tex. Rule Civ. Procedure 94, including the following: i. Garnishee Bank would show that with regard to any loan(s) or obligations due from the Owners/Signators on the Garnished Accounts, the Garnishee Bank reserves its rights of setoff or offset under common law, statutory law, and the documents signed by the parties to the Account (s)7 2. Any failure to give the Judgment Debtor Notice of this proceeding and a chance to object under Texas Rules of Civil Procedure 93(4) and 663a; 3. Any irregularities in the Application, Affidavit, any Bond and the Writ itself under Rule 663a and 679. Strict compliance is required; 4. Any irregularities in the time, method or manner of service under T.R.C.P. 662 and 663 (see also Motion to Quash below). Only Sheriffs and Constables may serve Writs and that service must be upon the designated agent for service of process; 5. Any misnomer of the Garnishee Bank or failure to properly name the Garnishee Bank, other than “Wells Fargo Bank, N.A.”;6. The rights of the Garnishee Bank under Texas Business & Commerce Code Ann. see. 4.303(a),(b), and footnotes thereto; 7. Any choice of-law-issues, conflicts, or applications. Plaintiffs and Judgment Debtors reside in, and possess accounts in, many different states; 8. Any misnomers, conflicts, or variations between (a) the legal name of the Defendant, (b) the name of the Judgment Debtor/Defendant (i) in the Final Judgment, (ii) in the Application for Garnishment, and (iii) in the Writs of Garnishment, and (c) the names on the Garnished Accounts in question; and 9. Any grounds set out in the “Motions to Quash Service and Writ(s) of Garnishment” set out below. VII. Motions to Quash Service and Writ(s) of Garnishment A. Texas Finance Code. The first ground of this Motion to Quash is that the Texas Finance Code sets out the exclusive method of perfecting service of a writ of garnishment upon a bank or financial institution.In no case shall judgment be rendered against any defendant unless upon service, or acceptance or waiver of process, as prescribed by these rules, except where otherwise expressly provided by law .. T.R.C.P. 124 (emphasis added). Section 63.008 of the Texas Civil Practice and Remedies Code controls the service of all Writs of Garnishment, including the one in issue. That section incorporates sec. 59.008, Texas Finance Code. See, Tex. Civil Prac. & Rem. Code Ann. Sec. 63.008. Section 59.008 of the Texas Finance Code Annotated states, “(a) claim against a customer of a financial institution shall be delivered .. at the address designated as the address of the registered agent .. in a registration filed with the secretary of state pursuant to Section 201. ..” Tex. Fin. Code Ann. Sec. 59.008 (Supp. 2003). Section 201.102 and 201.103 relate to the appointment of Yan agent authorized to receive service of process.” Tex. Fin. Code Ann. Sec. 201.103 (Supp. 2003). Garnishee Bank, in good faith, believes that it has complied with this section and appointed an agent for service of process by filing with the Texas Secretary of State, document #8832 on June 21, 2001, designating Corporation Service Company d/b/a “CSC” in Austin, Texas as its exclusive agent for service of process.Under Tex. Fin. Code sec. 59,008(c), the Judgment-Debtor (i.e. original Defendant) “bears the burden of preventing or limiting (the Garnishee Bank’s) compliance with or response to a claim subject to this section by seeking an appropriate remedy, including (T.R.O.), injunction, protective order, or other remedy ..” Therefore, Garnishee Bank is giving the Plaintiff notice of any deficiencies that exist in its service (and opportunity to cure) and the Judgment-Debtor time to seek appropriate remedies should he/she/they so choose. B. Irregularities in Service. Texas Rules of Civil Procedure 662 and 663 require service by a Sheriff or Constable, upon the Garnishee Bank's designated agent. Private process servers are prohibited. Strict compliance with these Rules is required. Garnishee Bank relies upon these Rules and any other irregularities in service that may exist as grounds for this Motion. Cc. Other Irregularities. Garnishee Bank further relies upon the grounds set out under VII entitled “Affirmative Defenses” and incorporates the allegations set out therein as if repeated verbatim as further grounds to quash the service as well as the Writ.WHEREFORE, PREMISES CONSIDERED, Garnishee Bank, WELLS FARGO BANK N.A., prays that the writ and service be quashed, the Judgment-Debtor be given notice of this action, that all issues be joined, that upon final hearing this Court discharge Garnishee Bank upon its Answer, that the Court enter other appropriate Orders fully protecting Garnishee Bank, that all costs be taxed against Garnishor, that Garnishee Bank be awarded reasonable attorneys' fees, and that Garnishee Bank be granted such other relief, legal or equitable, general or special, to which it may show itself justly entitled. Respectfully submitted, PEARSON, PEARSON, A Limited Liabilit rtnership By: PEARSON ta Bar No. 15691200 29 Weslayan St., Ste. 580 Hotton, Texas 77027-5132 13) 739-8600 TELE (713) 739-8341 FAX Pearsonpc@aol.com EMAIL ATTORNEYS FOR WELLS FARGO BANK N.A.TATAM re eos Yo. 0861 Po dpe. 28148 From: : To! 18666721561 Pitre VERIFTCAtTON TAR STATE or ARTAQNA 8 “ § COUNTY OF MARICOPA § BEFORE ME, the undersigned authority, on this day personally appeared the undersigned Person,.who first being duly sworn on his/her oath, stated and deposed ag follows: I am the one of the Custodians of the Records for WELLS FARGO BANK NVA. I am S ‘ over the age af eighteen, am competent ° . : te make this Affidavil, and fully authorized to make this Affidavit on behalt of weirs FARGO BANK N.A, I have sosd the Original answer to the Writ of Garnishment, havo Personal knowledge of the factual matter st out theyelu (based “pon a review at the Records of the Bank), and they are true aud correct, Whis verification doug not Opply to Fars. iy and Following, FURTHER AFFTAND SAvuTR Nor, SWORN 4O AND —— day ot hand and My Commission Expires: —__] nae Ree ener ne AAS F SARSON | . t =95%: MAY-32-2014 10:09AM From: TD: PEARSON Pasei@li R=95:CERTIFICATE OF SERVICE I do hereby certify that June 2 2014 a true and correct copy of the foregoing has been served upon PFISTER, BORSERINE & ASSOCIATES, P.L.L.C., by serving a copy upon his/her/their/its Attorney-of-record by facsimile -- return receipt requested; email (where requested) ; U.S. Mail postage pre-paid. :\WPD\937000\025\ PLEAD\ORIG ANS: PFISTER, BORSERINE & ASSOCIATES, P.L.L.C. vs. KARLA KENNARD June 2, 2014 Garnishees Original AnswerPearson & Pearson, L.L.P. ATTORNEYS AT LAW TELEPHONE (713) 739-8600 2900 Weslayan Street, Suite 580 E-MAIL: Pearsonpe@aol.com TELECOPIER (713) 739-8341 Houston, Texas 77027-5132 June 2, 2014 The Sherri Adelstein District Clerk - DENTON County County Courts Building, 1450 East McKinney Street, Suite 1200 P.O. Box 2146 Denton, Texas 76202-2146 Re: — Case No: 14-02825-431; 431ST JUDICIAL DISTRICT. PFISTER, BORSERINE & ASSOCIATES, P.L.L.C. v. KARLA KENNARD, et. al. Dear Clerk: We represent the Defendant, WELLS FARGO BANK N.A. in the above entitled and numbered cause of action. 1, With regard to this case, enclosed please find the Garnishee's Original Answer. 2. With regard to this and all other cases, please consider this our Notice of Change of Address for our law firm and all Attorneys. 3. Opposing counsel is being notified of the filing of the same, as shown below. 4. Please return the enclosed copy, file stamped, for our files. Yours truly, By: James H. Pearson Ences. CC. MR. JOHN J. PFISTER, JR. CC. MS. JULIE HEWITT - WELLS FAR ‘QAWPD19370001025\COR\ORIG.ANS Fax (972) 712-9205 Fax (866) 670-1561