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CAUSE NO.
CHANNEL PARTNERS CAPITAL, LLC IN THE DISTRICT COURT
Plaintiff
v
SAND TECH MANAGEMENT, LLC
AND JOHN TAYLOR
457% JUDICIAL DISTRICT
Defendants
AND
BRAZOS VALLEY SCHOOLS CREDIT
UNION
Garnishee MONTGOMERY COUNTY, TEXAS
APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT
1 Parties. Channel Partners Capital, LLC, Plaintiff in garnishment, whose address
is 10900 Wayzata Boulevard, Suite 300, Minnetonka, Minnesota 55305, makes this
Application for Writ of Garnishment after Judgment. Garnishee is Brazos Valley Schools Credit
Union, who may be served with citation by serving its Registered Agent, Courtney B. Poole, at
25525 Katy Mills Parkway, Katy, Texas 77494.
2 Facts. Plaintiff has a valid, subsisting judgment against Defendants Sand Tech
Management, LLC and John Taylor in Cause No. 42-CV-23-730, in the 5 Judicial District
Court, Lyon County, Minnesota, which was rendered on July 19, 2023. The judgment was
domesticated in the State of Texas, Cause No. 23-08-12228, in the 457" Judicial District Court,
Montgomery County, Texas on August 23, 2023. The amount on this judgment is $142,061.25 in
principal. This judgment is entitled to a credit of $369.34.
Defendant Sand Tech Management, LLC’s mailing address is 25211 Grogans Mill Road,
Suite 350, Spring, Texas 77380.
Defendant John Taylor’s mailing address is 11211 Bonham Rand Road, Dripping Springs,
Texas 78620.
Within Plaintiff's knowledge, Defendants do not possess property in Texas subject to
execution sufficient to satisfy the judgment. This garnishment is not sought to injure Defendants
or Garnishee.
3. 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.
4. 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 already rendered against Defendants, together with
interest and costs of the suit in the original case and in this garnishment
proceeding;
c. Plaintiff be granted judgment for pre-judgment and post-judgment interest
at the highest rate allowed by law; and
Plaintiff be granted all further relief to which Plaintiff may be entitled.
Respectfully Submitted,
LAM, LYN & PHILIP, P.C.
6363 Woodway Drive, Suite 975
Houston, Texas 77057
Telephone (713) 981-0900
Facsimile (713) 772-1085
Anita Jamali
State Bar No. 24110044
ajamali@llppc-law.com
Kurt L. Lyn
State Bar No. 00786078
klyn@llppe-law.com
Elizabeth Briscoe
State Bar No. 24107075
ebriscoe@llppc-law.com
Joni M. Fraser
State Bar No. 24089878
jfraser@llppe-law.com
Attorneys for Plaintiff
CAUSE NO.
CHANNEL PARTNERS CAPITAL, LLC IN THE DISTRICT COURT
Plaintiff
Vv
SAND TECH MANAGEMENT, LLC
AND JOHN TAYLOR
457% JUDICIAL DISTRICT
Defendants
AND
BRAZOS VALLEY SCHOOLS CREDIT
UNION
Garnishee MONTGOMERY COUNTY, TEXAS
AFFIDAVIT FOR WRIT OF GARNISHMENT AFTER JUDGMENT
BEFORE ME, the undersigned authority, on this day personally appeared Anita Jamali,
who swore on oath that the following facts are true:
“T am Plaintiff Channel Partners Capital, LLC’s attorney of record in this cause. I am
authorized to make this affidavit and application for a writ of garnishment in this cause.
I have personal knowledge of the facts stated in this affidavit, and they are true and correct.
Plaintiff owns a judgment against Defendants, Sand Tech Management, LLC and John
Taylor, which was rendered on July 19, 2023, by the 5¢ Judicial District Court, Lyon County,
Minnesota. The judgment is valid and subsisting, and a supersedeas bond has not been approved
and filed to suspend execution of the judgment. The amount on this judgment is $142,061.25 in
principal, said amount to include prejudgment interest and costs and disbursements. This judgment
is entitled to a credit of $369.34.
Within my knowledge, Defendants do not possess property in Texas subject to execution
sufficient to satisfy the judgment. My knowledge is based on a diligent search of the asset and
property records of Defendants in the Westlaw database. This garnishment is not sought to injure
Defendants or Garnishee.
I have reason to believe and do believe that Garnishee has property belonging to the
Defendants or is indebted to the Defendants. This belief is based on Plaintiffs due diligence.
bei
Anita Jamali, Affiant
SIGNED under oath before me on this RB 0 day of February 2024.
ae
a MAYRA MUNOZ
Notary Public, State of Texas:
Comm. Expires 04-11-2028 ayy Munro.
%y nw Notary ID 131083165 Notary Public, State of Texas
CU!
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CAUSE NO. CHANNEL PARTNERS CAPITAL, LLC IN THE DISTRICT COURT Plaintiff v SAND TECH MANAGEMENT, LLC AND JOHN TAYLOR 457% JUDICIAL DISTRICT Defendants AND BRAZOS VALLEY SCHOOLS CREDIT UNION Garnishee MONTGOMERY COUNTY, TEXAS APPLICATION FOR WRIT OF GARNISHMENT AFTER JUDGMENT 1 Parties. Channel Partners Capital, LLC, Plaintiff in garnishment, whose address is 10900 Wayzata Boulevard, Suite 300, Minnetonka, Minnesota 55305, makes this Application for Writ of Garnishment after Judgment. Garnishee is Brazos Valley Schools Credit Union, who may be served with citation by serving its Registered Agent, Courtney B. Poole, at 25525 Katy Mills Parkway, Katy, Texas 77494. 2 Facts. Plaintiff has a valid, subsisting judgment against Defendants Sand Tech Management, LLC and John Taylor in Cause No. 42-CV-23-730, in the 5 Judicial District Court, Lyon County, Minnesota, which was rendered on July 19, 2023. The judgment was domesticated in the State of Texas, Cause No. 23-08-12228, in the 457" Judicial District Court, Montgomery County, Texas on August 23, 2023. The amount on this judgment is $142,061.25 in principal. This judgment is entitled to a credit of $369.34. Defendant Sand Tech Management, LLC’s mailing address is 25211 Grogans Mill Road, Suite 350, Spring, Texas 77380. Defendant John Taylor’s mailing address is 11211 Bonham Rand Road, Dripping Springs, Texas 78620. Within Plaintiff's knowledge, Defendants do not possess property in Texas subject to execution sufficient to satisfy the judgment. This garnishment is not sought to injure Defendants or Garnishee. 3. 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. 4. 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 already rendered against Defendants, together with interest and costs of the suit in the original case and in this garnishment proceeding; c. Plaintiff be granted judgment for pre-judgment and post-judgment interest at the highest rate allowed by law; and Plaintiff be granted all further relief to which Plaintiff may be entitled. Respectfully Submitted, LAM, LYN & PHILIP, P.C. 6363 Woodway Drive, Suite 975 Houston, Texas 77057 Telephone (713) 981-0900 Facsimile (713) 772-1085 Anita Jamali State Bar No. 24110044 ajamali@llppc-law.com Kurt L. Lyn State Bar No. 00786078 klyn@llppe-law.com Elizabeth Briscoe State Bar No. 24107075 ebriscoe@llppc-law.com Joni M. Fraser State Bar No. 24089878 jfraser@llppe-law.com Attorneys for Plaintiff CAUSE NO. CHANNEL PARTNERS CAPITAL, LLC IN THE DISTRICT COURT Plaintiff Vv SAND TECH MANAGEMENT, LLC AND JOHN TAYLOR 457% JUDICIAL DISTRICT Defendants AND BRAZOS VALLEY SCHOOLS CREDIT UNION Garnishee MONTGOMERY COUNTY, TEXAS AFFIDAVIT FOR WRIT OF GARNISHMENT AFTER JUDGMENT BEFORE ME, the undersigned authority, on this day personally appeared Anita Jamali, who swore on oath that the following facts are true: “T am Plaintiff Channel Partners Capital, LLC’s attorney of record in this cause. I am authorized to make this affidavit and application for a writ of garnishment in this cause. I have personal knowledge of the facts stated in this affidavit, and they are true and correct. Plaintiff owns a judgment against Defendants, Sand Tech Management, LLC and John Taylor, which was rendered on July 19, 2023, by the 5¢ Judicial District Court, Lyon County, Minnesota. The judgment is valid and subsisting, and a supersedeas bond has not been approved and filed to suspend execution of the judgment. The amount on this judgment is $142,061.25 in principal, said amount to include prejudgment interest and costs and disbursements. This judgment is entitled to a credit of $369.34. Within my knowledge, Defendants do not possess property in Texas subject to execution sufficient to satisfy the judgment. My knowledge is based on a diligent search of the asset and property records of Defendants in the Westlaw database. This garnishment is not sought to injure Defendants or Garnishee. I have reason to believe and do believe that Garnishee has property belonging to the Defendants or is indebted to the Defendants. This belief is based on Plaintiffs due diligence. bei Anita Jamali, Affiant SIGNED under oath before me on this RB 0 day of February 2024. ae a MAYRA MUNOZ Notary Public, State of Texas: Comm. Expires 04-11-2028 ayy Munro. %y nw Notary ID 131083165 Notary Public, State of Texas CU!