Preview
Electronically Filed
4/26/2024 2:07 PM
Hidalgo County District Clerks
Reviewed By: Armando Cantu
C-1958-24-G
CAUSE NO.
PAGAYA AI DEBT SELECTION § IN THE DISTRICT COURT
GRANTOR TRUST 2021 3, §
serviced by UPGRADE, INC., §
Plaintiff, §
§
vs. § HIDALGO COUNTY, TEXAS
§
CAPITAL ONE BANK, N.A, §
Garnishee. § JUDICIAL DISTRICT
APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, the Plaintiff, P AGA YA AI DEBT SELECTION GRANTOR TRUST 2021
3, serviced by UPGRADE, INC. , and makes this its Application for a Writ of Garnishment After
Judgment, and in support thereof would show the Court the following:
I.
Parties
A Default Judgment was rendered in this cause of action on April 12, 2023. Plaintiff in
garnishment is PAGAYA AI DEBT SELECTION GRANTOR TRUST 2021 3, serviced by
UPGRADE, INC.
Garnishee is CAPITAL ONE BANK, N.A, a banking organization on which service of
process may be effectuated by serving its Registered Agent at CORPORATION SERVICE
COMPANY, 211 E. 7TH STREET, SUITE 620, AUSTIN, TEXAS 78701.
Judgment Defendant, MYRNA LOPEZ, may be served at 2099 W SANDSTONE DR,
MISSION, TX 78574.
Electronically Filed
4/26/2024 2:07 PM
Hidalgo County District Clerks
Reviewed By: Armando Cantu
C-1958-24-G
II.
Plaintiff has a valid, subsisting Judgment in the amount of$9 ,670. 72, and court costs, against
Defendant, MYRNA LOPEZ, whose address is 2099 W SANDSTONE DR, MISSION, TX 78574,
in Cause No. C-4742-22-G. To the best of 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. 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 rendered against Defendant, together
with costs in this garnishment proceeding; and
c. Plaintiff be granted all further relief to which Plaintiff may be entitled.
DeGrasse 20221578
Electronically Filed
4/26/2024 2:07 PM
Hidalgo County District Clerks
Reviewed By: Armando Cantu
C-1958-24-G
Respectfully submitted,
THE DeGRASSE LAW FIRM, P.C.
-~
BY: ----~~~~~~~-----------------
Donald D. DeGr se, SBN: 05641800
Beatrice Grevel, SBN: 00796677
1800 Bering Drive, Suite 460
Houston, Texas 77057
Tel: (713) 840-9111
Fax: (713) 840-7263
E-mail: attorneys@degrasselaw.com
ATTORNEYS FOR PLAINTIFF
DeGrasse 20221578
Electronically Filed
4/26/2024 2:07 PM
Hidalgo County District Clerks
Reviewed By: Armando Cantu
C-1958-24-G
CAUSE NO.
PAGAYA AI DEBT SELECTION § IN THE DISTRICT COURT
GRANTOR TRUST 2021 3, §
serviced by UPGRADE, INC., §
Plaintiff, §
§
vs. § HIDALGO COUNTY, TEXAS
§
CAPITAL ONE BANK, N.A, §
Garnishee. § JUDICIAL DISTRICT
AFFIDAVIT FOR WRIT OF GARNISHMENT AFTER JUDGMENT
BEFORE ME, the undersigned authority, on this day personally appeared Beatrice Grevel,
who swore on oath that the following facts are true:
1. "I am the attorney for the Plaintiff/Garnishor in this cause.
2. I am authorized to make this affidavit and application for a Writ of Garnishment in
this cause.
3. I have personal knowledge of the facts stated in this affidavit, and they are true and
correct.
4. Plaintiff/Garnishor owns a Judgment against MYRNA LOPEZ, Judgment Defendant,
which was rendered on April12, 2023, in the amount of$9,670.72 and court costs. 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 $10,132.44, in addition to
costs of this proceeding.
5. To the best of my 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. Plaintiff/Garnishor conducted Post Judgment Discovery
DeGrasse 202215 7 8
Electronically Filed
4/26/2024 2:07 PM
Hidalgo County District Clerks
Reviewed By: Armando Cantu
C-1958-24-G
on MYRNA LOPEZ, with no response, and recorded an Abstract of Judgment in the HIDALGO
County public records on 5/31 /2023 .
6. I have reason to believe that Garnishee has property belonging to Judgment Defendant
or is indebted to Judgment Defendant. This belief is based on a bank account number acquired
through discovery or previous payments made by the Judgment Defendant, whose social security
number ends in (***-**-*752). Judgment Defendant's date ofbirth is September 17, 1973.
Beatrice Grevel ..........,....
SIGNED under oath before me on this th day of April, 2024.
JASMINE HOUSTON
Notary ID #1315321 17
My Commission Expires
Apri/19 , 2026
DeGr asse 202 215 78
Preview
Electronically Filed 4/26/2024 2:07 PM Hidalgo County District Clerks Reviewed By: Armando Cantu C-1958-24-G CAUSE NO. PAGAYA AI DEBT SELECTION § IN THE DISTRICT COURT GRANTOR TRUST 2021 3, § serviced by UPGRADE, INC., § Plaintiff, § § vs. § HIDALGO COUNTY, TEXAS § CAPITAL ONE BANK, N.A, § Garnishee. § JUDICIAL DISTRICT APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, the Plaintiff, P AGA YA AI DEBT SELECTION GRANTOR TRUST 2021 3, serviced by UPGRADE, INC. , and makes this its Application for a Writ of Garnishment After Judgment, and in support thereof would show the Court the following: I. Parties A Default Judgment was rendered in this cause of action on April 12, 2023. Plaintiff in garnishment is PAGAYA AI DEBT SELECTION GRANTOR TRUST 2021 3, serviced by UPGRADE, INC. Garnishee is CAPITAL ONE BANK, N.A, a banking organization on which service of process may be effectuated by serving its Registered Agent at CORPORATION SERVICE COMPANY, 211 E. 7TH STREET, SUITE 620, AUSTIN, TEXAS 78701. Judgment Defendant, MYRNA LOPEZ, may be served at 2099 W SANDSTONE DR, MISSION, TX 78574. Electronically Filed 4/26/2024 2:07 PM Hidalgo County District Clerks Reviewed By: Armando Cantu C-1958-24-G II. Plaintiff has a valid, subsisting Judgment in the amount of$9 ,670. 72, and court costs, against Defendant, MYRNA LOPEZ, whose address is 2099 W SANDSTONE DR, MISSION, TX 78574, in Cause No. C-4742-22-G. To the best of 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. 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 rendered against Defendant, together with costs in this garnishment proceeding; and c. Plaintiff be granted all further relief to which Plaintiff may be entitled. DeGrasse 20221578 Electronically Filed 4/26/2024 2:07 PM Hidalgo County District Clerks Reviewed By: Armando Cantu C-1958-24-G Respectfully submitted, THE DeGRASSE LAW FIRM, P.C. -~ BY: ----~~~~~~~----------------- Donald D. DeGr se, SBN: 05641800 Beatrice Grevel, SBN: 00796677 1800 Bering Drive, Suite 460 Houston, Texas 77057 Tel: (713) 840-9111 Fax: (713) 840-7263 E-mail: attorneys@degrasselaw.com ATTORNEYS FOR PLAINTIFF DeGrasse 20221578 Electronically Filed 4/26/2024 2:07 PM Hidalgo County District Clerks Reviewed By: Armando Cantu C-1958-24-G CAUSE NO. PAGAYA AI DEBT SELECTION § IN THE DISTRICT COURT GRANTOR TRUST 2021 3, § serviced by UPGRADE, INC., § Plaintiff, § § vs. § HIDALGO COUNTY, TEXAS § CAPITAL ONE BANK, N.A, § Garnishee. § JUDICIAL DISTRICT AFFIDAVIT FOR WRIT OF GARNISHMENT AFTER JUDGMENT BEFORE ME, the undersigned authority, on this day personally appeared Beatrice Grevel, who swore on oath that the following facts are true: 1. "I am the attorney for the Plaintiff/Garnishor in this cause. 2. I am authorized to make this affidavit and application for a Writ of Garnishment in this cause. 3. I have personal knowledge of the facts stated in this affidavit, and they are true and correct. 4. Plaintiff/Garnishor owns a Judgment against MYRNA LOPEZ, Judgment Defendant, which was rendered on April12, 2023, in the amount of$9,670.72 and court costs. 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 $10,132.44, in addition to costs of this proceeding. 5. To the best of my 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. Plaintiff/Garnishor conducted Post Judgment Discovery DeGrasse 202215 7 8 Electronically Filed 4/26/2024 2:07 PM Hidalgo County District Clerks Reviewed By: Armando Cantu C-1958-24-G on MYRNA LOPEZ, with no response, and recorded an Abstract of Judgment in the HIDALGO County public records on 5/31 /2023 . 6. I have reason to believe that Garnishee has property belonging to Judgment Defendant or is indebted to Judgment Defendant. This belief is based on a bank account number acquired through discovery or previous payments made by the Judgment Defendant, whose social security number ends in (***-**-*752). Judgment Defendant's date ofbirth is September 17, 1973. Beatrice Grevel ..........,.... SIGNED under oath before me on this th day of April, 2024. JASMINE HOUSTON Notary ID #1315321 17 My Commission Expires Apri/19 , 2026 DeGr asse 202 215 78