Context source · GT-S-E037287D7182
e037287d718284a2221e…0 pages · 180 KBDISTILLATES
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Plaintiffs claim that 30 days have passed since the October 28, 2024 hearing and judgment-debtors have not filed any court document evidencing a stay of the Virginia litigation or judgment.
Thirty (30) days have past and Judgment-Debtors have not filed one court document evidencing a Stay of the Virginia litigation or judgment.
Court denied judgment-debtors' Motion to Vacate but granted a 30-day stay contingent on providing documentation evidencing a stay of the Virginia judgment.
The court denied Judgment-Debtors' Motion to Vacate but granted a thirty (30) day stay so that Judgment-Defendants could provide the court with documentation evidencing a Stay of the Virginia judgment.
Plaintiffs assert that judgment-debtors made only partial payments from October 2023 through May 2024, with no payments made since June 2024, contrary to defendants' representation of full payment compliance.
Now Counsel for Judgment-Debtors represent Within their Motion to Extend Stay that Judgment-Debtors have made all payments due. Only partial payments were made from October 2023 through May 2024. No payments have been made since June 2024.
Plaintiffs claim no stay was ever entered or contemplated in the Virginia litigation, and the Virginia court has allowed collection activity to continue, releasing garnished funds in August 2024.
No stay was ever entered in the Virginia litigation. No stay was even contemplated. Contrarily, the Virginia court has allowed collection activity to continue and released funds garnished in Virginia to plaintiffs in August.
Plaintiffs assert that judgment-debtors waived all rights of appeal, reconsideration, and bankruptcy discharge as stated in Paragraph B of the Final Judgment.
Lastly, Judgment-Debtors waived all rights of appeal, reconsideration and bankruptcy, as permitted by law. Paragraph B of the Final Judgment states in part: "The parties agree that the final judgment shall not be dischargeable in bankruptcy to the fullest extent permissible at law, and Defendants hereby waive all rights of reconsideration and appeal."
Plaintiffs claim defense counsel misrepresented that Virginia litigation attacks judgment validity or seeks reformation, when the actual complaints filed do not mention these issues.
Next, they represented that the Virginia litigation attacks the validity of the Judgment and asks for reformation of the Judgment. That is not true. Plaintiffs have provided the actual complaint filed by Defendants to Judgment-Debtors' Counsel. Those complaints do not mention the validity of the Judgment or reformation whatsoever.
Plaintiffs characterize judgment-debtors' motions as frivolous, not supported by facts, and designed to delay and impede collection actions.
Judgment-Debtor continues to file frivolous motions, not supported by facts but rather designed to delay and impede Plaintiffs' collection actions.
Plaintiff and judgment-creditor seeking to enforce judgment against Cyberlux Corporation and Mark Schmidt in Harris County District Court.
ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC ("Plaintiffs") and files this Reply to Defendants
Co-plaintiff and judgment-creditor pursuing collection enforcement alongside Atlantic Wave Holdings, LLC.
ATLANTIC WAVE HOLDINGS, LLC and SECURE COMMUNITY, LLC ("Plaintiffs")
Defendant and judgment-debtor subject to collection enforcement efforts in Harris County and Virginia.
CYBERLUX CORPORATION and MARK SCHMIDT'S ("Defendants") Opposition to Judgment-Debtors' Motion to Extend Stay of Execution
Individual defendant and judgment-debtor named alongside Cyberlux Corporation in collection proceedings.
CYBERLUX CORPORATION and MARK SCHMIDT, Individually, Defendant/Judgment-Debtors.
Houston-based law firm representing plaintiffs/judgment-creditors in collection enforcement actions.
LAW FIRM OF SHAWN M. GRADY, PLLC By: /s/ Shawn MCGrady Shawn M Grady SBN 24076411 Shawn@Gradycollectionlaw.Com 2100 West Loop South, Ste. 805 Houston, Texas 77027
Dallas-based law firm representing defendants/judgment-debtors in the Harris County litigation.
Katherine Battaia Clark State Bar No. 24046712 THOMPSON COBURN LLP 2100 Ross Avenue, Suite 3200 Dallas, Texas 75201
Court hearing on defendants' Motion to Vacate and Motion to Stay Execution, resulting in denial of Motion to Vacate but granting of 30-day stay conditioned on providing Virginia stay documentation.
On October 28, 2024, the court heard Defendants' Motion to Vacate and Motion to Stay Execution. The court denied Judgment-Debtors' Motion to Vacate but granted a thirty (30) day stay so that Judgment-Defendants could provide the court with documentation evidencing a Stay of the Virginia judgment.
Plaintiffs filed opposition to judgment-debtors' motion to extend stay of execution, asserting defendants failed to meet 30-day deadline for Virginia stay documentation.
12/2/2024 10:14 AM Marilyn Burgess - District Clerk Harris County Envelope No. 94814652 By: Chancesas Ougrah Filed: 12/2/2024 10:14 AM
Virginia court released garnished funds to plaintiffs in August 2024, indicating continuation of collection activity in Virginia jurisdiction.
Contrarily, the Virginia court has allowed collection activity to continue and released funds garnished in Virginia to plaintiffs in August.
Judgment-debtors made partial payments from October 2023 through May 2024, with no payments made since June 2024 according to plaintiffs.
Only partial payments were made from October 2023 through May 2024. No payments have been made since June 2024.
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