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FILED
2/6/2024 12:59 PM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Belinda Hernandez DEPUTY
DC-24-01936
CAUSE NO.
MEMBERS 1ST FEDERAL CREDIT § IN THE DISTRICT COURT
UNION, serviced by UPGRADE, INC., §
Plaintiff, §
§
vs. § DALLASCOUNTY,TEXAS
§
WELLS FARGO BANK, N.A., § 134th
Garnishee. § _ _ _ JUDICIAL DISTRICT
APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT
TO THE HONORABLE JUDGE OF SAID COURT:
COMES NOW, the Plaintiff, MEMBERS 1ST FEDERAL CREDIT UNION, 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 22, 2023. Plaintiff in
garnishment is MEMBERS 1ST FEDERAL CREDIT UNION, serviced by UPGRADE, INC.
Garnishee is WELLS FARGO BANK, N.A., a banking organization on which service of
process may be effectuated by serving its Registered Agent, CORPORATION SERVICE
COMPANY dba CSC-LAWYERS INCORPORATING SERVICE, 211 E 7TH STREET, SUITE
620, AUSTIN, TEXAS 78701.
Defendant, DIS HEN A BLACK, may be served with Citation at 3320 HUDNALL ST, 251 H,
DALLAS, TX 75235.
II.
Plaintiff has a valid, subsisting Judgment against Defendant, whose address is 3320
HUDNALL ST,251H, DALLAS, TX 75235 , in Cause No. DC-23-00722 in theamountof$9,557.20
and court costs. To the best ofPlaintiffs 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 Plaintiffs Judgment rendered against Defendant, together
with costs of this garnishment proceeding; and
c. Plaintiff be granted all further relief to which Plaintiff may be entitled.
DeGras se 2 0 22 16 28
Respectfully submitted,
THE DeGRASSE LAW FIRM, P.C.
BY: ~~_.,~
Do~d D:DeaSSe, SBN: 05641800
Beatrice Grevel, SBN: 00796677
1800 Bering Drive, Suite 460
Houston, Texas 77057
Tel: (713) 840-9111
Fax: (713) 840-7263
E-mail: attomeys@degrasselaw.com
ATTORNEYS FOR PLAINTIFF
De Gra sse 20 2 2 1 6 2 8
CAUSE NO DC-23-00722
MEMBERS 1ST FEDERAL CREDIT § IN THE DISTRICT COURT
UNION, serviced by UPGRADE, INC., §
Plaintiff, §
§
VL § DALLAS COUNTY, TEXAS
§
WELLS FARGO 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/Gamishor 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/Gamishor owns a Judgment against Judgment Defendant, which was
rendered on April22, 2023, by the Court in the amount of$9,557.20 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 $10,018.92 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
on DISHENA BLACK, without receiving a response, and recorded an Abstract of Judgment in the
DeGrasse 202 2 1628
DALLAS County official public records on July 6, 2023.
6. I have reason to believe that Garnishee has ssets 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 (***-**-*281). Judgment Defendant's date ofbirth is July 26, 1987.
SIGNED under oath before me on this 6th day of February, 2024.
JASMINE HOUSTON
Notary ID #13 1532117
My Commission Expires
April 19, 2026
DeGrasse 20 221 628
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FILED 2/6/2024 12:59 PM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Belinda Hernandez DEPUTY DC-24-01936 CAUSE NO. MEMBERS 1ST FEDERAL CREDIT § IN THE DISTRICT COURT UNION, serviced by UPGRADE, INC., § Plaintiff, § § vs. § DALLASCOUNTY,TEXAS § WELLS FARGO BANK, N.A., § 134th Garnishee. § _ _ _ JUDICIAL DISTRICT APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, the Plaintiff, MEMBERS 1ST FEDERAL CREDIT UNION, 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 22, 2023. Plaintiff in garnishment is MEMBERS 1ST FEDERAL CREDIT UNION, serviced by UPGRADE, INC. Garnishee is WELLS FARGO BANK, N.A., a banking organization on which service of process may be effectuated by serving its Registered Agent, CORPORATION SERVICE COMPANY dba CSC-LAWYERS INCORPORATING SERVICE, 211 E 7TH STREET, SUITE 620, AUSTIN, TEXAS 78701. Defendant, DIS HEN A BLACK, may be served with Citation at 3320 HUDNALL ST, 251 H, DALLAS, TX 75235. II. Plaintiff has a valid, subsisting Judgment against Defendant, whose address is 3320 HUDNALL ST,251H, DALLAS, TX 75235 , in Cause No. DC-23-00722 in theamountof$9,557.20 and court costs. To the best ofPlaintiffs 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 Plaintiffs Judgment rendered against Defendant, together with costs of this garnishment proceeding; and c. Plaintiff be granted all further relief to which Plaintiff may be entitled. DeGras se 2 0 22 16 28 Respectfully submitted, THE DeGRASSE LAW FIRM, P.C. BY: ~~_.,~ Do~d D:DeaSSe, SBN: 05641800 Beatrice Grevel, SBN: 00796677 1800 Bering Drive, Suite 460 Houston, Texas 77057 Tel: (713) 840-9111 Fax: (713) 840-7263 E-mail: attomeys@degrasselaw.com ATTORNEYS FOR PLAINTIFF De Gra sse 20 2 2 1 6 2 8 CAUSE NO DC-23-00722 MEMBERS 1ST FEDERAL CREDIT § IN THE DISTRICT COURT UNION, serviced by UPGRADE, INC., § Plaintiff, § § VL § DALLAS COUNTY, TEXAS § WELLS FARGO 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/Gamishor 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/Gamishor owns a Judgment against Judgment Defendant, which was rendered on April22, 2023, by the Court in the amount of$9,557.20 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 $10,018.92 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 on DISHENA BLACK, without receiving a response, and recorded an Abstract of Judgment in the DeGrasse 202 2 1628 DALLAS County official public records on July 6, 2023. 6. I have reason to believe that Garnishee has ssets 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 (***-**-*281). Judgment Defendant's date ofbirth is July 26, 1987. SIGNED under oath before me on this 6th day of February, 2024. JASMINE HOUSTON Notary ID #13 1532117 My Commission Expires April 19, 2026 DeGrasse 20 221 628