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FILED
1/4/2022 11:54 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Kevin Molden DEPUTY
CAUSE NO. DC 21-18053
HARRISON COMPANY, L.L.C., § IN THE DISTRICT COURT OF
§
Plaintiff, §
§
v. § DALLAS COUNTY, TEXAS
§
A-Z WHOLESALERS INC. and §
BARKAT G. ALI, §
§
Defendants. § L-193rd JUDICIAL DISTRICT
AMENDED NOTICE OF FILING OF FOREIGN JUDGMENT
Pursuant to the Uniform Enforcement of Foreign Judgments Act, Tex. Civ. Prac. & Rem.
Code §§ 35.001 et seq., Harrison Company, L.L.C. (“Harrison” or the “Judgment Creditor”) hereby
files the Final Judgment (“Judgment”) and Bill of Costs rendered in the United States District
Court for the Northern District of Texas, Dallas Division, for enforcement in Texas, and
respectfully shows the Court:
1. This Court has jurisdiction to enforce the judgments of federal courts, and is an
appropriate venue for such enforcement. See Tex. Civ. Prac. & Rem. Code § 35.003; Tanner v.
McCarthy, 274 S.W.3d 311, 320 (Tex. App.—Houston [1st Dist.] 2008, no pet.); Navigant
Consulting, Inc. v. Taulman, No. 05-10-00775-CV, 2012 WL 219338, at *3 (Tex. App.—Dallas
January 25, 2012, no pet).
2. Attached hereto as Exhibit 1 and incorporated herein by reference for all purposes
is the Affidavit of Nicholas S. Graber (the “Affidavit”), that, among other things, authenticates the
Final Judgment and Bill of Costs and identifies the Judgment Creditor and A-Z Wholesalers Inc.
and Barkat G. Ali (the “Judgment Debtors”) and their respective last known addresses. A true and
1
correct certified copy of the Judgment is attached to the Affidavit as Exhibit A. A true and correct
certified copy of the Bill of Costs is attached to the Affidavit as Exhibit B.
3. The Affidavit authenticates for filing in this Court the Judgment and Bill of Costs
attached to it, which are public records, certified under official seal by a Clerk of the United States
District Court for the Northern District of Texas. The Judgment and Bill of Costs attached to the
Affidavit were rendered in a lawsuit in the United States District Court for the Northern District
of Texas styled Harrison Company, L.L.C. v. A-Z Wholesalers Inc. and Barkat G. Ali, Civil Action
No. 3:19-CV-1057-B.
4. The name and current post office address of the Judgment Creditor are:
Harrison Company, L.L.C.
4801 Viking Dr.
Bossier City, LA 71111
See Ex. 1 at ¶¶ 2-3.
5. The names and last known post office addresses of the Judgment Debtors are:
A-Z Wholesalers Inc.
11100 Harry Hines Blvd.
Dallas, TX 75229
and
Barkat G. Ali
616 Clariden Ranch Rd.
Southlake, TX 76092
See Ex. 1 at ¶¶ 4-5.
6. The Amended Notice of Filing of Foreign Judgment will be mailed to A-Z
Wholesalers Inc. at the Harry Hines Blvd. address. The Amended Notice of Filing of Foreign
Judgment will be mailed to Barkat G. Ali at the Clariden Ranch Rd. address. Tex. Civ. Prac. &
Rem. Code § 35.004(b).
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7. The name, address, and contact information of the Judgment Debtors’ attorney are
as follows:
Warren V. Norred
NORRED LAW, PLLC
515 E. Border
Arlington Texas 76010
Telephone: 817-704-3984
warren@norredlaw.com
See Ex. 1 at ¶ 6.
8. The Amended Notice of Filing of Foreign Judgment will be mailed to the Judgment
Debtors’ attorney at the E. Border address. Tex. Civ. Prac. & Rem. Code § 35.004(b).
9. The names, addresses, and contact information of the Judgment Creditor’s
attorneys are as follows:
David L. Swanson
dswanson@lockelord.com
LOCKE LORD LLP
2200 Ross Avenue, Suite 2800
Dallas, Texas 75201
T: 214-740-8000
F: 214-740-8800
Thomas F. Loose
tloose@lockelord.com
LOCKE LORD LLP
2200 Ross Avenue, Suite 2800
Dallas, Texas 75201
T: 214-740-8000
F: 214-740-8800
Nicholas S. Graber
nick.graber@lockelord.com
LOCKE LORD LLP
2200 Ross Avenue, Suite 2800
Dallas, Texas 75201
T: 214-740-8000
F: 214-740-8800
See Ex. 1 at ¶ 7.
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10. Accordingly, Judgment Creditor requests that the clerk and the Court treat the
attached Judgment and Bill of Costs of the United States District Court for the Northern District
of Texas in the same manner as, and as having the same effect of, a final judgment and bill of costs
in this Court.
Respectfully submitted,
/s/ Nicholas S. Graber
David L. Swanson
State Bar No. 19554625
dswanson@lockelord.com
Thomas F. Loose
State Bar No. 12561500
tloose@lockelord.com
Nicholas S. Graber
State Bar. No. 24122918
nick.graber@lockelord.com
LOCKE LORD LLP
2200 Ross Avenue, Suite 2800
Dallas, Texas 75201-6776
T: 214-740-8000
F: 214-740-8800
ATTORNEYS FOR PLAINTIFF
HARRISON COMPANY, L.L.C.
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Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Rick Hagerich on behalf of Nicholas Graber
Bar No. 24122918
rhagerich@lockelord.com
Envelope ID: 60467024
Status as of 1/5/2022 10:58 AM CST
Associated Case Party: HARRISON COMPANY LLC
Name BarNumber Email TimestampSubmitted Status
David Swanson dswanson@lockelord.com 1/4/2022 11:54:54 AM SENT
Thomas Loose tloose@lockelord.com 1/4/2022 11:54:54 AM SENT
Nicholas S.Graber Nick.Graber@lockelord.com 1/4/2022 11:54:54 AM SENT
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FILED 1/4/2022 11:54 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Kevin Molden DEPUTY CAUSE NO. DC 21-18053 HARRISON COMPANY, L.L.C., § IN THE DISTRICT COURT OF § Plaintiff, § § v. § DALLAS COUNTY, TEXAS § A-Z WHOLESALERS INC. and § BARKAT G. ALI, § § Defendants. § L-193rd JUDICIAL DISTRICT AMENDED NOTICE OF FILING OF FOREIGN JUDGMENT Pursuant to the Uniform Enforcement of Foreign Judgments Act, Tex. Civ. Prac. & Rem. Code §§ 35.001 et seq., Harrison Company, L.L.C. (“Harrison” or the “Judgment Creditor”) hereby files the Final Judgment (“Judgment”) and Bill of Costs rendered in the United States District Court for the Northern District of Texas, Dallas Division, for enforcement in Texas, and respectfully shows the Court: 1. This Court has jurisdiction to enforce the judgments of federal courts, and is an appropriate venue for such enforcement. See Tex. Civ. Prac. & Rem. Code § 35.003; Tanner v. McCarthy, 274 S.W.3d 311, 320 (Tex. App.—Houston [1st Dist.] 2008, no pet.); Navigant Consulting, Inc. v. Taulman, No. 05-10-00775-CV, 2012 WL 219338, at *3 (Tex. App.—Dallas January 25, 2012, no pet). 2. Attached hereto as Exhibit 1 and incorporated herein by reference for all purposes is the Affidavit of Nicholas S. Graber (the “Affidavit”), that, among other things, authenticates the Final Judgment and Bill of Costs and identifies the Judgment Creditor and A-Z Wholesalers Inc. and Barkat G. Ali (the “Judgment Debtors”) and their respective last known addresses. A true and 1 correct certified copy of the Judgment is attached to the Affidavit as Exhibit A. A true and correct certified copy of the Bill of Costs is attached to the Affidavit as Exhibit B. 3. The Affidavit authenticates for filing in this Court the Judgment and Bill of Costs attached to it, which are public records, certified under official seal by a Clerk of the United States District Court for the Northern District of Texas. The Judgment and Bill of Costs attached to the Affidavit were rendered in a lawsuit in the United States District Court for the Northern District of Texas styled Harrison Company, L.L.C. v. A-Z Wholesalers Inc. and Barkat G. Ali, Civil Action No. 3:19-CV-1057-B. 4. The name and current post office address of the Judgment Creditor are: Harrison Company, L.L.C. 4801 Viking Dr. Bossier City, LA 71111 See Ex. 1 at ¶¶ 2-3. 5. The names and last known post office addresses of the Judgment Debtors are: A-Z Wholesalers Inc. 11100 Harry Hines Blvd. Dallas, TX 75229 and Barkat G. Ali 616 Clariden Ranch Rd. Southlake, TX 76092 See Ex. 1 at ¶¶ 4-5. 6. The Amended Notice of Filing of Foreign Judgment will be mailed to A-Z Wholesalers Inc. at the Harry Hines Blvd. address. The Amended Notice of Filing of Foreign Judgment will be mailed to Barkat G. Ali at the Clariden Ranch Rd. address. Tex. Civ. Prac. & Rem. Code § 35.004(b). 2 7. The name, address, and contact information of the Judgment Debtors’ attorney are as follows: Warren V. Norred NORRED LAW, PLLC 515 E. Border Arlington Texas 76010 Telephone: 817-704-3984 warren@norredlaw.com See Ex. 1 at ¶ 6. 8. The Amended Notice of Filing of Foreign Judgment will be mailed to the Judgment Debtors’ attorney at the E. Border address. Tex. Civ. Prac. & Rem. Code § 35.004(b). 9. The names, addresses, and contact information of the Judgment Creditor’s attorneys are as follows: David L. Swanson dswanson@lockelord.com LOCKE LORD LLP 2200 Ross Avenue, Suite 2800 Dallas, Texas 75201 T: 214-740-8000 F: 214-740-8800 Thomas F. Loose tloose@lockelord.com LOCKE LORD LLP 2200 Ross Avenue, Suite 2800 Dallas, Texas 75201 T: 214-740-8000 F: 214-740-8800 Nicholas S. Graber nick.graber@lockelord.com LOCKE LORD LLP 2200 Ross Avenue, Suite 2800 Dallas, Texas 75201 T: 214-740-8000 F: 214-740-8800 See Ex. 1 at ¶ 7. 3 10. Accordingly, Judgment Creditor requests that the clerk and the Court treat the attached Judgment and Bill of Costs of the United States District Court for the Northern District of Texas in the same manner as, and as having the same effect of, a final judgment and bill of costs in this Court. Respectfully submitted, /s/ Nicholas S. Graber David L. Swanson State Bar No. 19554625 dswanson@lockelord.com Thomas F. Loose State Bar No. 12561500 tloose@lockelord.com Nicholas S. Graber State Bar. No. 24122918 nick.graber@lockelord.com LOCKE LORD LLP 2200 Ross Avenue, Suite 2800 Dallas, Texas 75201-6776 T: 214-740-8000 F: 214-740-8800 ATTORNEYS FOR PLAINTIFF HARRISON COMPANY, L.L.C. 4 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Rick Hagerich on behalf of Nicholas Graber Bar No. 24122918 rhagerich@lockelord.com Envelope ID: 60467024 Status as of 1/5/2022 10:58 AM CST Associated Case Party: HARRISON COMPANY LLC Name BarNumber Email TimestampSubmitted Status David Swanson dswanson@lockelord.com 1/4/2022 11:54:54 AM SENT Thomas Loose tloose@lockelord.com 1/4/2022 11:54:54 AM SENT Nicholas S.Graber Nick.Graber@lockelord.com 1/4/2022 11:54:54 AM SENT