On June 10, 2021 a
Complaint,Petition
was filed
involving a dispute between
Enerbank Usa,
and
Beck, Jacqueline R.,
for Contract Consumer/Commercial/Debt >$200,000
in the District Court of Montgomery County.
Preview
Received and E-Filed for Record
6/10/2021 10:50 AM
Melisa Miller, District Clerk
CAUSE NO. 21-06-08099 Montgomery County, Texas
Deputy Clerk, Rachel Gallagher
ENERBANK USA § IN THE DISTRICT COURT
§
vs. § MONTGOMERY COUNTY, TEXAS
§ Montgomery County - 284th Judicial District Court
WELLS FARGO BANK, N.A., §
Garnishee, § _________ JUDICIAL DISTRICT
APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, the Plaintiff/Garnishor, ENERBANK USA and makes this its Application
for a Writ of Garnishment After Judgment and in support thereof would show the Court the
following:
I.
Parties
Plaintiff/Garnishor in garnishment is ENERBANK USA .
Garnishee, WELLS FARGO BANK, N.A. is a banking organization on which service of
process may be effectuated by serving its Registered Agent, at CORPORATION SERVICE
COMPANY dba CSC-LAWYERS INCORPORATING, 211 E 7TH STREET, SUITE 620,
AUSTIN, TEX.
Defendant, JACQUELINE R. BECK , who may be served with Citation at 931 REPUBLIC
RD, NEW CANEY TX 77357.
II.
Facts
Plaintiff/Garnishor has a valid, subsisting Judgment against Judgment Defendant, Judgment
was rendered on June 5, 2019 in Cause No. 19-02-02633 in this Court in the amount of $6,089.32;
6.99% Per annum contractual pre-judgment interest on the balance from the date of judgment;
$2,008.82 Attorney’s fees; plus Costs of Court; and 6.99% Per annum contractual post-judgment
DeGrasse 20180401
interest on the Judgment amount until paid in full. Within Plaintiff/Garnishor’s knowledge,
Judgment Defendant does not possess property in Texas subject to execution sufficient to satisfy the
Judgment. This garnishment is not sought to injure Judgment Defendant or Garnishee.
III.
Affidavit
Plaintiff/Garnishor 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.
Prayer
Plaintiff/Garnishor prays that –
a. Writ of Garnishment be issued directed to Garnishee;
b. Plaintiff/Garnishor be granted Judgment against Garnishee for the amount now due
on Plaintiff/Garnishor’s Judgment already rendered against Judgment Defendant,
together with costs of the suit in the original case and in this garnishment proceeding;
c. Plaintiff/Garnishor be granted all further relief to which Plaintiff/Garnishor may be
entitled.
Respectfully submitted,
THE DeGRASSE LAW FIRM, P.C.
BY:_______________________________
Donald D. DeGrasse
SBN: 05641800
Eric M. Spence
SBN: 24070658
Beatrice Grevel
SBN: 00796677
Leonidia “Leo” Vidal Glasper
SBN: 24111179
1800 Bering Drive, Suite 1000
Houston, Texas 77057
Tel: (713) 840-9111
Fax: (713) 840-7263
E-mail: attorneys@degrasselaw.com
ATTORNEYS FOR PLAINTIFF
DeGrasse 20180401
Document Filed Date
June 10, 2021
Case Filing Date
June 10, 2021
Category
Contract Consumer/Commercial/Debt >$200,000
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Received and E-Filed for Record 6/10/2021 10:50 AM Melisa Miller, District Clerk CAUSE NO. 21-06-08099 Montgomery County, Texas Deputy Clerk, Rachel Gallagher ENERBANK USA § IN THE DISTRICT COURT § vs. § MONTGOMERY COUNTY, TEXAS § Montgomery County - 284th Judicial District Court WELLS FARGO BANK, N.A., § Garnishee, § _________ JUDICIAL DISTRICT APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, the Plaintiff/Garnishor, ENERBANK USA and makes this its Application for a Writ of Garnishment After Judgment and in support thereof would show the Court the following: I. Parties Plaintiff/Garnishor in garnishment is ENERBANK USA . Garnishee, WELLS FARGO BANK, N.A. is a banking organization on which service of process may be effectuated by serving its Registered Agent, at CORPORATION SERVICE COMPANY dba CSC-LAWYERS INCORPORATING, 211 E 7TH STREET, SUITE 620, AUSTIN, TEX. Defendant, JACQUELINE R. BECK , who may be served with Citation at 931 REPUBLIC RD, NEW CANEY TX 77357. II. Facts Plaintiff/Garnishor has a valid, subsisting Judgment against Judgment Defendant, Judgment was rendered on June 5, 2019 in Cause No. 19-02-02633 in this Court in the amount of $6,089.32; 6.99% Per annum contractual pre-judgment interest on the balance from the date of judgment; $2,008.82 Attorney’s fees; plus Costs of Court; and 6.99% Per annum contractual post-judgment DeGrasse 20180401 interest on the Judgment amount until paid in full. Within Plaintiff/Garnishor’s knowledge, Judgment Defendant does not possess property in Texas subject to execution sufficient to satisfy the Judgment. This garnishment is not sought to injure Judgment Defendant or Garnishee. III. Affidavit Plaintiff/Garnishor 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. Prayer Plaintiff/Garnishor prays that – a. Writ of Garnishment be issued directed to Garnishee; b. Plaintiff/Garnishor be granted Judgment against Garnishee for the amount now due on Plaintiff/Garnishor’s Judgment already rendered against Judgment Defendant, together with costs of the suit in the original case and in this garnishment proceeding; c. Plaintiff/Garnishor be granted all further relief to which Plaintiff/Garnishor may be entitled. Respectfully submitted, THE DeGRASSE LAW FIRM, P.C. BY:_______________________________ Donald D. DeGrasse SBN: 05641800 Eric M. Spence SBN: 24070658 Beatrice Grevel SBN: 00796677 Leonidia “Leo” Vidal Glasper SBN: 24111179 1800 Bering Drive, Suite 1000 Houston, Texas 77057 Tel: (713) 840-9111 Fax: (713) 840-7263 E-mail: attorneys@degrasselaw.com ATTORNEYS FOR PLAINTIFF DeGrasse 20180401