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NO
FOX CAPITAL GROUP, INC. § IN THE DISTRICT COURT
§
§
VS. §
§
§
TEJCEK ENTERPRISES, LLC and § JUDICIAL DISTRICT
DUSTIN TEJCEK §
§
VS. §
FIRST BANK OF CONROE, N.A. § MONTGOMERY COUNTY, TEXAS
PLAINTIFF'S APPLICATION FOR
WRIT OF GARNISHMENT AFTER JUDGMENT
TO THE HONORABLE JUDGE OF SAID COURT:
I. Parties
A Plaintiff, FOX CAPITAL GROUP, INC., hereby applies for a writ of garnishment
after judgment.
B Garnishee, FIRST BANK OF CONROE, N.A. may be served by serving its
registered agent, Ken Mayfield or any officer or agent at 1800 West White Oak Terrace, Conroe,
Texas 77304.
Cc. Defendant, TEJCEK ENTERPRISES, LLC, may be sent notice by Plaintiff of
this garnishment proceeding at 15953 Highway 105 W., Montgomery, Texas 77356.
D. Defendant, DUSTIN TEJCEK may be sent notice by Plaintiff
of this garnishment
proceeding at 16020 Fountainview Drive, Montgomery, Texas 77356.
II.Facts
Plaintiff has a valid, subsisting judgment against Defendants, domesticated on October 2,
2018, in this Court, under cause number 18-10-13251. Plaintiff has reason to believe and does
believe that Garnishee has property belonging to Defendants or is indebted to Defendants. Within
Plaintiff's knowledge, Defendants do not possess property within the State that is subject to
execution and that is sufficient to satisfy the judgment. This garnishment is not sought on or sought
to injure Defendants or Garnishee.
III. Affidavit
Plaintiff
is entitled to the issuance ofa 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.
IH. Prayer
Plaintiff prays that:
1 a writ of garnishment be issued directed to Garnishee, FIRST BANK OF
CONROE, N.A.
2 Defendants be served by Plaintiff with a copy of the writ of garnishment, this
application, and accompanying affidavit;
3 Plaintiff be granted judgment against Garnishee for $28,796.80 as the amount of
Plaintiff's judgment already rendered against Defendants, together with other costs and interest in
connection with this garnishment proceeding, with the total not to exceed the amount admitted or
found to be due Defendants from Garnishee;
4. Plaintiff be granted judgment for post-judgment interest on the judgment in this
garnishment proceeding at the rate of five percent (5%) per year on the total amount of the
judgment in this proceeding from the date of judgment until paid; and
5 Plaintiff be granted such other and further relief, special or general, legal or
equitable, as Plaintiff may be shown to be justly entitled.
Respectfully submitted,
ALAN R. EINTHAL
TBC# 17 640
Attorney at Law
4635 Southwest Freeway, Suite 720
Houston, Texas 77027
(713) 871-8040 (Telephone)
(713) 871-8642 (Telecopier)
ascheinthal@ScheinthalLawFirm.com
ATTORNEY FOR PLAINTIFF
NO.
FOX CAPITAL GROUP, INC. § IN THE DISTRICT COURT
VS.
TEJCEK ENTERPRISES, LLC and JUDICIAL DISTRICT
DUSTIN TEJCEK
VS.
FIRST BANK OF CONROE, N.A. § MONTGOMERY COUNTY, TEXAS
AFFIDAVIT FOR WRIT OF GARNISHMENT AFTER JUDGMENT
THE STATE OF TEXAS §
COUNTY OF HARRIS
BEFORE ME, the undersigned authority, on this day personally appeared Alan R.
Scheinthal, who, being by me duly sworn on oath stated:
"Iam Plaintiff's attorney in this cause. I have personal knowledge of the facts stated
in this affidavit, and they are true and correct. I am authorized to make this affidavit
and application for a writ of garnishment.”
"Plaintiff owns a judgment against Defendants which was domesticated on October
2, 2018, 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
sum of $28,796.80, plus costs of court in connection with this garnishment
proceeding is now due and unpaid on the judgment.”
"Within my knowledge, Defendants do not possess property within the state that is
subject to execution and that is sufficient to satisfy the judgment. This garnishment
is not sought out to injure either Defendants or Garnishees.”
"I have reason to believe and do believe that Garnishees have property belonging
to Defendants or are indebted to Defendants."
’
Alan R. S nthal
SUBSCRIBED AND SWORN TO BEFORE ME, this lH te day of October, 2023, to
certify which witness my hand and official seal.
JULI HARTMAN
IN
Notary ID #132549839
My Commission
otary Public in and for
Expires
duly 1, 2024 he State of Texas
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NO FOX CAPITAL GROUP, INC. § IN THE DISTRICT COURT § § VS. § § § TEJCEK ENTERPRISES, LLC and § JUDICIAL DISTRICT DUSTIN TEJCEK § § VS. § FIRST BANK OF CONROE, N.A. § MONTGOMERY COUNTY, TEXAS PLAINTIFF'S APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT TO THE HONORABLE JUDGE OF SAID COURT: I. Parties A Plaintiff, FOX CAPITAL GROUP, INC., hereby applies for a writ of garnishment after judgment. B Garnishee, FIRST BANK OF CONROE, N.A. may be served by serving its registered agent, Ken Mayfield or any officer or agent at 1800 West White Oak Terrace, Conroe, Texas 77304. Cc. Defendant, TEJCEK ENTERPRISES, LLC, may be sent notice by Plaintiff of this garnishment proceeding at 15953 Highway 105 W., Montgomery, Texas 77356. D. Defendant, DUSTIN TEJCEK may be sent notice by Plaintiff of this garnishment proceeding at 16020 Fountainview Drive, Montgomery, Texas 77356. II.Facts Plaintiff has a valid, subsisting judgment against Defendants, domesticated on October 2, 2018, in this Court, under cause number 18-10-13251. Plaintiff has reason to believe and does believe that Garnishee has property belonging to Defendants or is indebted to Defendants. Within Plaintiff's knowledge, Defendants do not possess property within the State that is subject to execution and that is sufficient to satisfy the judgment. This garnishment is not sought on or sought to injure Defendants or Garnishee. III. Affidavit Plaintiff is entitled to the issuance ofa 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. IH. Prayer Plaintiff prays that: 1 a writ of garnishment be issued directed to Garnishee, FIRST BANK OF CONROE, N.A. 2 Defendants be served by Plaintiff with a copy of the writ of garnishment, this application, and accompanying affidavit; 3 Plaintiff be granted judgment against Garnishee for $28,796.80 as the amount of Plaintiff's judgment already rendered against Defendants, together with other costs and interest in connection with this garnishment proceeding, with the total not to exceed the amount admitted or found to be due Defendants from Garnishee; 4. Plaintiff be granted judgment for post-judgment interest on the judgment in this garnishment proceeding at the rate of five percent (5%) per year on the total amount of the judgment in this proceeding from the date of judgment until paid; and 5 Plaintiff be granted such other and further relief, special or general, legal or equitable, as Plaintiff may be shown to be justly entitled. Respectfully submitted, ALAN R. EINTHAL TBC# 17 640 Attorney at Law 4635 Southwest Freeway, Suite 720 Houston, Texas 77027 (713) 871-8040 (Telephone) (713) 871-8642 (Telecopier) ascheinthal@ScheinthalLawFirm.com ATTORNEY FOR PLAINTIFF NO. FOX CAPITAL GROUP, INC. § IN THE DISTRICT COURT VS. TEJCEK ENTERPRISES, LLC and JUDICIAL DISTRICT DUSTIN TEJCEK VS. FIRST BANK OF CONROE, N.A. § MONTGOMERY COUNTY, TEXAS AFFIDAVIT FOR WRIT OF GARNISHMENT AFTER JUDGMENT THE STATE OF TEXAS § COUNTY OF HARRIS BEFORE ME, the undersigned authority, on this day personally appeared Alan R. Scheinthal, who, being by me duly sworn on oath stated: "Iam Plaintiff's attorney in this cause. I have personal knowledge of the facts stated in this affidavit, and they are true and correct. I am authorized to make this affidavit and application for a writ of garnishment.” "Plaintiff owns a judgment against Defendants which was domesticated on October 2, 2018, 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 sum of $28,796.80, plus costs of court in connection with this garnishment proceeding is now due and unpaid on the judgment.” "Within my knowledge, Defendants do not possess property within the state that is subject to execution and that is sufficient to satisfy the judgment. This garnishment is not sought out to injure either Defendants or Garnishees.” "I have reason to believe and do believe that Garnishees have property belonging to Defendants or are indebted to Defendants." ’ Alan R. S nthal SUBSCRIBED AND SWORN TO BEFORE ME, this lH te day of October, 2023, to certify which witness my hand and official seal. JULI HARTMAN IN Notary ID #132549839 My Commission otary Public in and for Expires duly 1, 2024 he State of Texas