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Received and E-Filed for Record
6/15/2016 12:35:35 PM
16-06-06978 Barbara Gladden Adamick
CAUSE NO. District Clerk
Montgomery County, Texas
AMERICAN EXPRESS CENTURION BANK § IN THE DISTRICT COURT OF
§
§
vs. § MONTGOMERY COUNTY, TEXAS
§
JPMORGAN CHASE BANK, N.A., §
Garnishee § 284th JUDICIAL DISTRICT
APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, the Plaintiff, AMERICAN EXPRESS CENTURION BANK and makes this
its Application for a Writ of Gamishment After Judgment and in support thereof would show the
Court the following:
1.
Parties
Judgment was rendered in this cause of action on December 14, 2015. Plaintiff in
garnishment is AMERICAN EXPRESS CENTURION BANK.
Garnishee, JPMORGAN CHASE BANK, N.A. is a banking organization on which service
of process may be effectuated by serving its Registered Agent, CT CORPORATION SYSTEM at
1999 BRYAN ST, SUITE 900, DALLAS, TEXAS 75201, DALLAS County.
Defendant, MORGAN A. THOMAS may be served with a copy of this Application at P,O.
BOX 8697, SPRING, TEXAS 77381, MONTGOMERY County, pursuant to Rule 21 a of the Texas
Rules of Civil Procedure.
II.
Facts
Plaintiff has a valid, subsisting Judgment against Defendant, MORGAN A. THOMAS, in
Cause No. 14~06-06674 in this Court in the amount of $10,880.80 plus Costs of 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.
III.
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.
Prayer
Plaintiff prays that -
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 costs of the suit in the original case and in this
garnishment proceeding;
c. Plaintiff be granted all further relief to which Plaintiff may be entitled.
Respectfully submitted,
DeGRASSE & ROLNICK
By:
Donald D. DeGrasse
SBN: 05641800
ddegrasse@degrasserolnick.com
Lori M. Davlin
SBN: 24088870
ldavlin@degrasserolnick.com
Clint Raney
SBN: 24047734
craneV®degrasserolnick.com
1800 Bering. Suite 1000
Houston, Texas 77057
Tel: (713) 840-9111
Fax: (713) 840-7263
ATTORNEYSFORPLA~TWF
CAUSE NO.
AMERICAN EXPRESS CENTURION BANK § IN THE DISTRICT COURT OF
§
§
vs. § MONTGOMERY COUNTY, TEXAS
§
JPMORGAN CHASE BANK, N.A., §
Garnishee § 284th JUDICIAL DISTRICT
AFFIDAVIT FOR WRIT OF GARNISHMENT AFTER JUDGMENT
BEFORE ME, the undersigned authority, on this day personally appeared Donald D.
DeGrasse, who swore on oath that the following facts are true:
1. "1 am the attorney for the Plaintiff in this cause.
2. I am authorized to make this affidavit and application for a Writ of Gamishment in
this cause.
3. I have personal knowledge of the facts stated in this affidavit, and they are true and
correct.
4. Plaintiff owns a Judgment against MORGAN A. THOMAS, Defendant, which was
rendered on December 14,2015 by this Court in the amount 0[$1 0,880.80 plus Costs of Court. The
Judgment is valid and subsisting, and a supersedeas bond has not been approved and filed to suspend
execution afthe Judgment. The amount now due and unpaid on the Judgment is $11,266.07.
5. Within my 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.
6. I have reason to believe and do believe that Garnishee has property belonging to
Defendant or is indebted to Defendant. This belief is based on bank account number acquired
through discovery or previous payments made by the Defendant whose social security number ends
in ("'''''''-*'''-'''893).
Donald D. DeGrasse, Affiant
SIGNED under oath before me on this qt~ay of } " - ' .i ,2016,
Notary Public, State of Texas
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Received and E-Filed for Record 6/15/2016 12:35:35 PM 16-06-06978 Barbara Gladden Adamick CAUSE NO. District Clerk Montgomery County, Texas AMERICAN EXPRESS CENTURION BANK § IN THE DISTRICT COURT OF § § vs. § MONTGOMERY COUNTY, TEXAS § JPMORGAN CHASE BANK, N.A., § Garnishee § 284th JUDICIAL DISTRICT APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, the Plaintiff, AMERICAN EXPRESS CENTURION BANK and makes this its Application for a Writ of Gamishment After Judgment and in support thereof would show the Court the following: 1. Parties Judgment was rendered in this cause of action on December 14, 2015. Plaintiff in garnishment is AMERICAN EXPRESS CENTURION BANK. Garnishee, JPMORGAN CHASE BANK, N.A. is a banking organization on which service of process may be effectuated by serving its Registered Agent, CT CORPORATION SYSTEM at 1999 BRYAN ST, SUITE 900, DALLAS, TEXAS 75201, DALLAS County. Defendant, MORGAN A. THOMAS may be served with a copy of this Application at P,O. BOX 8697, SPRING, TEXAS 77381, MONTGOMERY County, pursuant to Rule 21 a of the Texas Rules of Civil Procedure. II. Facts Plaintiff has a valid, subsisting Judgment against Defendant, MORGAN A. THOMAS, in Cause No. 14~06-06674 in this Court in the amount of $10,880.80 plus Costs of 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. III. 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. Prayer Plaintiff prays that - 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 costs of the suit in the original case and in this garnishment proceeding; c. Plaintiff be granted all further relief to which Plaintiff may be entitled. Respectfully submitted, DeGRASSE & ROLNICK By: Donald D. DeGrasse SBN: 05641800 ddegrasse@degrasserolnick.com Lori M. Davlin SBN: 24088870 ldavlin@degrasserolnick.com Clint Raney SBN: 24047734 craneV®degrasserolnick.com 1800 Bering. Suite 1000 Houston, Texas 77057 Tel: (713) 840-9111 Fax: (713) 840-7263 ATTORNEYSFORPLA~TWF CAUSE NO. AMERICAN EXPRESS CENTURION BANK § IN THE DISTRICT COURT OF § § vs. § MONTGOMERY COUNTY, TEXAS § JPMORGAN CHASE BANK, N.A., § Garnishee § 284th JUDICIAL DISTRICT AFFIDAVIT FOR WRIT OF GARNISHMENT AFTER JUDGMENT BEFORE ME, the undersigned authority, on this day personally appeared Donald D. DeGrasse, who swore on oath that the following facts are true: 1. "1 am the attorney for the Plaintiff in this cause. 2. I am authorized to make this affidavit and application for a Writ of Gamishment in this cause. 3. I have personal knowledge of the facts stated in this affidavit, and they are true and correct. 4. Plaintiff owns a Judgment against MORGAN A. THOMAS, Defendant, which was rendered on December 14,2015 by this Court in the amount 0[$1 0,880.80 plus Costs of Court. The Judgment is valid and subsisting, and a supersedeas bond has not been approved and filed to suspend execution afthe Judgment. The amount now due and unpaid on the Judgment is $11,266.07. 5. Within my 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. 6. I have reason to believe and do believe that Garnishee has property belonging to Defendant or is indebted to Defendant. This belief is based on bank account number acquired through discovery or previous payments made by the Defendant whose social security number ends in ("'''''''-*'''-'''893). Donald D. DeGrasse, Affiant SIGNED under oath before me on this qt~ay of } " - ' .i ,2016, Notary Public, State of Texas