Document for KERRY BURNS et al vs. TEXANS CREDIT UNION

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                                AUSE     . 14-___________

                    ERRY AND       ARIE     URNS                                           N THE           ISTRICT     OURT

                                 Plaintiff                                                     ALLAS     OUNTY      EXAS




                    EXANS     REDIT     NION




                              LAINTIFFS        PPLICATION FOR           RIT OF      ARNISHMENT AFTER            UDGMENT

                           Plaintiffs  are  Kerry and    Marie   Burns,   who   hereby apply for      a writ  of  garnishment    after

                  judgment.     Garnishee    i  Texans    Credit  Union,    which   can  be  served   with  process   by serving    its

                  Manager/CEO,       Kevin    Durrance,    at 777   E.  Campbell     Rd.,  Richardson,    TX     75081     Debtor    is

                  Rex D. Redden.

                                                              Notice of Related Case

                           Pursuant to Local Rule 1.08, this case is related to Cause No. 08-13839 styled Kerry and

                  Marie Burns v. Rex Redden, et al             he 191st Judicial District Court.



                          Plaintiff  has  a  valid,  subsisting   judgment     against   Debtor,   whose    last known     address   is

                  1440 Carrollton Parkway,         #3101    Carrollton, TX      75010.    Plaintiffs have    reason   to believe and

                  do believe that Garnishee has property belonging to Debtor or is indebted to Debtor pursuant to a

                  banking     relationship    admitted    by   Debtor    in  post-judgment       discovery       Within    Plaintiffs

                  knowledge,     Debtor    do     not  possess    property    within   the  state  that  is  subject   to  execution

                  sufficient to satisfy the judgment.       This garnishment is not sought to injure Debtor or Garnishee.




                   LAINTIFFS    PPLICATION FOR     RIT O    ARNISHMENT AFTER     UDGMENT                                         AGE
                                                                        II.

                          Plaintiffs are entitled to the issuance of a writ of garnishment on the grounds stated in the

                  attached   affidavit.   The   affidavit  is incorporated     into this  application   by reference    as  if copied

                  herein verbatim.

                                                                        III.

                          This   is an  attempt    to  collect  a  debt   and  any   information      obtained    will  be  used   for

                  that purpose.

                                                                      PRAYER

                           Plaintiffs pray that:

                           1.       A writ of garnishment be issued directed to Garnishee;

                           2.       Plaintiffs     be    granted     judgment       against     Garnishee       for    $158,836.08

                  comprising      principal   and   accrued     interest  on   the  underlying     judgment      plus   $430.00    for

                  costs of this garnishment proceeding; and,

                           3.       Plaintiffs  be   granted   such   other  and   further  relief,  special  or  general,   legal  or

                  equitable, as may be shown that Plaintiffs are justly entitled to receive.

                                                                                 Respectfully submitted,

                                                                                 /s/ David R. Gibson
                                                                                 ______________________
                                                                                 David R. Gibson
                                                                                 SBN 07861220
                                                                                 3102 Maple Ave., Ste. 400
                                                                                 Dallas, TX 75201
                                                                                 (214) 800-2213
                                                                                 (214) 800-2214 (fax)

                                                                                 COUNSEL FOR PLAINTIFFS




                  PLAINTIFFS’ APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT                                                PAGE 2