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3/18/2014 10:39:43 AM
Amalia Rodriguez-Mendoza
District Clerk
Travis County
Cause No, D-1-GN-14-000803 D-1-GN-14-000803
ERIN G. FITZER, § IN THE DISTRICT COURT OF
Plaintiff in Garnishment, :
V. : 98TH JUDICIAL DISTRICT
JP MORGAN CHASE, NA, :
Garnishee. : TRAVIS COUNTY, TEXAS
APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT.
1. Parties - Erin Fitzer, Plaintiff in Garnishment, whose address is 815-A Brazos St.
#58, Austin, TX 78701, makes this Application for Writ of Garnishment after Judgment.
Garnishee is JP Morgan Chase, NA, who may be served with citation through its registered agent
CT Corporation System at 1999 Bryan St., Suite 900, Dallas, Texas 75201-3136.
2. Facts. Plaintiff has a valid, subsisting judgment against Defendant, Brian P.
Gleason, whose address is 4800 Counts Cove, Austin, Texas 78749, in Cause No. D-1-FM-12-
004512 in this Court. Within Plaintiff's knowledge, Defendant does not possess property in
Texas subject to execution sufficient to satisfy the judgment. This garnishment is not sought to
injure Defendant or Garnishee.
3. Affidavit. Plaintiff is entitled to the issuance of a writ of garnishment on the
grounds stated in the attached affidavit. The affidavit is incorporated in this application by
reference.
4. Prayer. Plaintiff prays that—
a. a writ of garnishment be issued directed to Garnishee;
b. Plaintiff be granted judgment against Garnishee for the amount now due
on Plaintiff's judgment already rendered against Defendant, together with
interest and costs of the suit in the original case and in this garnishment
proceeding;
c. Plaintiff be granted judgment for prejudgment and postjudgment interest
at the highest rate allowed by law; and
d. Plaintiff be granted all further relief to which Plaintiff may be entitled.March 14, 2014
Respectfully submitted,
REID COLLINS & TSAI LLP
1301 S. Capital of Texas Hwy
Suite C300
Austin, TX 78746
T: 512-647-6100
F: 512-647-6129
/s/ Sean D. Johnson
Sean D. Johnson
Texas Bar No. 24055746
Attorneys for Plaintiff in Garnishment
ERIN G, FITZERCause No.
ERIN G. FITZER, § IN THE DISTRICT COURT OF
Plaintiff in Garnishment, ;
V. 5 98TH JUDICIAL DISTRICT
JP MORGAN CHASE, NA, 5
Garnishee. ; TRAVIS COUNTY, TEXAS
AFFIDAVIT FOR WRIT OF GARNISHMENT AFTER JUDGMENT
BEFORE ME, the undersigned authority, on this day personally appeared Sean D.
Johnon, who swore on oath that the following facts are true:
“I am Plaintiffs counsel in this cause. I am authorized to make this affidavit and
application for a writ of garnishment in this cause.
I have personal knowledge of the facts stated in this affidavit, and they are true and
correct.
Plaintiff in Garnishment owns a judgment against Brian P. Gleason, Defendant in
Garnishment, which was rendered on March 11, 2014 by this Court. The judgment is valid and
subsisting, and a supersedeas bond has not been approved and filed to suspend execution of the
judgment. The amount now due and unpaid on the judgment is $24,768.84 plus interest.
Within my knowledge, Defendant in Garnishment does not possess property in Texas
subject to execution sufficient to satisfy the judgment. This garnishment is not sought to injure
Defendant in Garnishment or Garnishee.
I have reason to believe and do believe that Garnishee has property belonging to
Defendant or is indebted to Defendant. This belief i is based on Plaintiff i in Garnishment personal
knowledge.” ~ -
Sean D. Johnson
Sworn to and subscribed before me by Sean D. Johnson on March 14, 2014.MINA NAPOLES MYERS
MY COMMISSION EXPIRES
dune 14, 2016
My commission expires:
GY,
Notary Public in and for
the State of Texas
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3/18/2014 10:39:43 AM Amalia Rodriguez-Mendoza District Clerk Travis County Cause No, D-1-GN-14-000803 D-1-GN-14-000803 ERIN G. FITZER, § IN THE DISTRICT COURT OF Plaintiff in Garnishment, : V. : 98TH JUDICIAL DISTRICT JP MORGAN CHASE, NA, : Garnishee. : TRAVIS COUNTY, TEXAS APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT. 1. Parties - Erin Fitzer, Plaintiff in Garnishment, whose address is 815-A Brazos St. #58, Austin, TX 78701, makes this Application for Writ of Garnishment after Judgment. Garnishee is JP Morgan Chase, NA, who may be served with citation through its registered agent CT Corporation System at 1999 Bryan St., Suite 900, Dallas, Texas 75201-3136. 2. Facts. Plaintiff has a valid, subsisting judgment against Defendant, Brian P. Gleason, whose address is 4800 Counts Cove, Austin, Texas 78749, in Cause No. D-1-FM-12- 004512 in this Court. Within Plaintiff's knowledge, Defendant does not possess property in Texas subject to execution sufficient to satisfy the judgment. This garnishment is not sought to injure Defendant or Garnishee. 3. Affidavit. Plaintiff is entitled to the issuance of a writ of garnishment on the grounds stated in the attached affidavit. The affidavit is incorporated in this application by reference. 4. Prayer. Plaintiff prays that— a. a writ of garnishment be issued directed to Garnishee; b. Plaintiff be granted judgment against Garnishee for the amount now due on Plaintiff's judgment already rendered against Defendant, together with interest and costs of the suit in the original case and in this garnishment proceeding; c. Plaintiff be granted judgment for prejudgment and postjudgment interest at the highest rate allowed by law; and d. Plaintiff be granted all further relief to which Plaintiff may be entitled.March 14, 2014 Respectfully submitted, REID COLLINS & TSAI LLP 1301 S. Capital of Texas Hwy Suite C300 Austin, TX 78746 T: 512-647-6100 F: 512-647-6129 /s/ Sean D. Johnson Sean D. Johnson Texas Bar No. 24055746 Attorneys for Plaintiff in Garnishment ERIN G, FITZERCause No. ERIN G. FITZER, § IN THE DISTRICT COURT OF Plaintiff in Garnishment, ; V. 5 98TH JUDICIAL DISTRICT JP MORGAN CHASE, NA, 5 Garnishee. ; TRAVIS COUNTY, TEXAS AFFIDAVIT FOR WRIT OF GARNISHMENT AFTER JUDGMENT BEFORE ME, the undersigned authority, on this day personally appeared Sean D. Johnon, who swore on oath that the following facts are true: “I am Plaintiffs counsel in this cause. I am authorized to make this affidavit and application for a writ of garnishment in this cause. I have personal knowledge of the facts stated in this affidavit, and they are true and correct. Plaintiff in Garnishment owns a judgment against Brian P. Gleason, Defendant in Garnishment, which was rendered on March 11, 2014 by this Court. The judgment is valid and subsisting, and a supersedeas bond has not been approved and filed to suspend execution of the judgment. The amount now due and unpaid on the judgment is $24,768.84 plus interest. Within my knowledge, Defendant in Garnishment does not possess property in Texas subject to execution sufficient to satisfy the judgment. This garnishment is not sought to injure Defendant in Garnishment or Garnishee. I have reason to believe and do believe that Garnishee has property belonging to Defendant or is indebted to Defendant. This belief i is based on Plaintiff i in Garnishment personal knowledge.” ~ - Sean D. Johnson Sworn to and subscribed before me by Sean D. Johnson on March 14, 2014.MINA NAPOLES MYERS MY COMMISSION EXPIRES dune 14, 2016 My commission expires: GY, Notary Public in and for the State of Texas