in Re Amy Williams

Opinion

ACCEPTED

01-15-00685-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS 8/14/2015 11:29:19 AM CHRISTOPHER PRINE

CLERK

No. 01-15-00685-CV

FILED IN

IN THE FIRST COURT OF APPEALS 1st COURT OF APPEALS HOUSTON, TEXAS

HOUSTON, TEXAS 8/14/2015 11:29:19 AM CHRISTOPHER A. PRINE

Clerk

IN RE AMY WILLIAMS,

Relator.

Original Proceeding from the 3 09"’ Judicial District Court Harris County, Texas, Hon. Sheri Y. Dean, Judge Presiding

REAL PARTY IN INTEREST’S RESPONSE TO RELATOR’S MOTION FOR EMERGENCY RELIEF

TO THE HONORABLE FIRST COURT OF APPEALS:

Real Party in Interest Harold Holmes (“Holmes”) files this Real Party in

Interest’s Response to the Motion for Emergency Relief to the Relator’s Motion

for Emergency Temporary Relief filed by Relator Amy Williams (“Williams”),

and in support thereof, respectfully shows as follows.

1. On June 19, 2009, Judge Frank Rynd, of the 309” Judicial District

Court of Harris County, signed the Order, which related to the payment and

collection of child support arrearages and attomey’s fees, which is attached hereto

as Exhibit “A,” and incorporated for all purposes herein.

2. On July 17, 2009, Holmes’s attorney filed a Motion to Modtfv,

Correct, or Reform Judgment, which related to the payment and collection of child support arrearages and attomey’s fees, which is attached hereto as Exhibit

“B,” and incorporated for all purposes herein.

3. On October 1, 2009, this Court signed the Final Reformed Order,

which is the current order governing the payment and collection of child support

arrearages and attomey’s fees, which is attached hereto as Exhibit “C,” and

incorporated for all purposes herein.

4. Since 2009, the enforcement and collection methods taken by

Williams and her counsel have been an issue in this case. Following Judge Rynd’s

Order signed on June 19, 2009, William’s counsel issued a “Judicial Writ of

Income Withholding to Employer” that withheld $2,311.95 a month without the

Court’s approval of such amount, which is attached as Exhibit A to the Motion to

Modify, Correct, or Reform Judgment, see attached Exhibit “B.” Following the

hearing on Holmes’s Motion to Modify, Correct, or Reform Judgment—which

considered William’s ability to issue a withholding order for collection of child

suppoIt—Judge Rynd made specific rulings regarding the enforcement and

collection of child support arrearages and attorney’s fees in this matter in his Final

Reformed Order, specifically limiting the monthly amount to be withheld and

specific limitations on enforcing the order, see attached Exhibit “C.”

It is important to note that in both the Order, signed on June 19, 2009 and

the Final Reformed Order, Judge Rynd ordered that Williams was only given a judgment for attorney’s fees and gave Williams no authority to withhold for the

attomey’s fees awarded.

Section l58.005l(a) of the Texas Family Code, upon in which Williams

relies, states that: “In addition to an order for income to be withheld for child

support, including child support and child support arrearages, the court may render

an order that income be withheld from the disposable earning of the obligor to be

applied towards the satisfaction of any ordered attomey’s fees and costs resulting

from an action to enforce child support under this title.” Although Judge Rynd had

authority to issue a wage withholding order for attomey’s fees in this matter, per

Section l58.005l(a), the decision to allow a wage withholding order for this

purpose was at his discretion and Judge Rynd, in fact, did not order wage

withholding for attorney’s fees in this case.

5. On July 28, 2015, when counsel appeared before the Court, the

Honorable Judge Sheri Y. Dean, did not have the ability to hear this case due to the

Court’s docket on that date. In an effort to manage the Court’s docket, Judge Dean

reset this case for hearing on October 2, 2015. Also on July 28, 2015, Judge Dean

ordered that the child support withholding order be temporarily stayed until the

Court could hear this matter on October 2, 2015. Judge Dean clearly stated to

counsel that the withholding order would resume, in the event that the Court found

outstanding child support arrearages. In accordance with Judge Dean’s ruling,

Holmes’s counsel submitted two proposed orders to effectuate Judge Dean’s

ruling. The first order, signed by Associate Judge Beverly Malazzo, terminated

withholding for child support until October 2, 2015, which is attached hereto as

Exhibit “D,” and incorporated for all purposes herein. The second order, also

signed by Associate Judge Beverly Malazzo, resumes withholding for child

support on October 2, 2015, which is attached hereto as Exhibit “E,” and

incorporated for all purposes herein. In the event that Judge Dean determines that

child support is owed at the October 2, 2015 hearing, the withholding order will be

in place. Williams claim that this case requires emergency relief is inaccurate

because, as the orders stand now, withholding from Holmes’s wages resumes on

October 2, 2015, unless there is ruling in Holmes’s favor by Judge Dean on that

date.

6. In the Final Reformed Order described above, Holmes was ordered to

make all payments through the Texas Child Support State Disbursement Unit, P.O.

Box 659791, San Antonio, Texas 78265-9791. The Texas Child Support

Disbursement Unit Payment Record is attached hereto as Exhibit “F,” and

incorporated for all purposes herein. This payment record shows that as of August

13, 2015, Harold Holmes has paid approximately $53,781.85 through the Texas

Child Support Disbursement Unit. Williams complains that because Holmes’s

pleadings stated, as of June 2016, there was a remaining balance the obligation remained unsatisfied. However, as of July 28, 2015, as demonstrated by Holmes’s

child support payments in the month of July (as of the date of the hearing in

question) Holmes had paid his child support obligation to Amy Williams in full.

The requested relief by Williams is to continue to garnish Holmes’s

income through a wage withholding order for attorney's fees, which is

improper and was specifically not ordered by Iudge Rynd in the Final

Reformed Order.

CONCLUSION AND PRAYER

For all of the foregoing reasons, Real Party in Interest Harold Holmes

respectfully prays that the Court deny Relat0r’s Motion for Emergency

Temporary Relief.

Respectfiilly submitted,

FULLENWEIDER WILHITE

By: Lauren E. Waddell /s/

Lauren E. Waddell State Bar No. 24036440 4265 San Felipe Street, Suite 1400 Houston, Texas 77027 Telephone: (713) 624-4100 Facsimile: (713) 624-4141 E-mail: lwaddellgwfullenweidercom ATTORNEY FOR REAL PARTY IN INTEREST HAROLD HOLMES

By: /s/ John A. Ramirez John Anthony Ramirez State Bar No. oo7848o8 917 Franklin, Suite 510 Houston, Texas 77002 Telephone: (713) 224-9900 Facsimile: (713) 224-9903 E-mail: jaramirez.law@gmail.com ATTORNEY FOR REAL PARTY IN INTEREST HAROLD HOLMES

CERTIFICATE OF COMPLIANCE Pursuant to Texas Rule of Appellate Procedure 9.4(i)(3), I hereby certify that this response was prepared in Times New Roman 14-point font, and contains 929 words, and that this number was calculated using the word count program of Microsoft Word, which is the program that was used to prepare this document.

/s/ Lauren E. Waddell

Lauren E. Waddell

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing Real Party in Interesfs Response to Relator’s Motion for Emergency Relief has been served electronically via e-filing on the following counsel of record, this 14th day of August, 2015:

Honorable Sheri Y. Dean District Judge, 309'h Judicial District Court of Harris County, Texas 201 Caroline, 16”‘ Floor

Houston, Texas 77002

Steven A. Sinkin Andrew Ross Sinkin Law Firm 105 West Woodlawn San Antonio, Texas 78212

/s/Lauren E. Waddell Lauren E. Waddell

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000 7 03 0.2a ‘3\/

L iiiex Cause No. 703634]

In the Interest of

I.

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D D In the District Court

Glenna Noel Holmes 3309'“ Judicial District

A Child Harris County, Texas

On December 18, 2007, came on to be hcard Amy Williams’ 0riginalAnswer and Afiinnative Relief and Request for Sanctions, Original Answer to Intervention and Request for

Sanctions, and First Amended Original Answer to First Amended Intervention and Request for

Sanctions, Sinkin & Barretto, P.L.L.C.’s Original Answer to Second Amended Intervention

and Request for Sanctions, Karen Marvel‘s Original Answer to Second Amended Intervention

and Request for Sanctions, Harold‘ F. Holmes’ Emergency Motion to Release Child Support

and/or to Dispute the Amount ofArrearages Stated in Child Support Lien and/or to Resolve

Ownership Interest with Respect to Property Subject to Child Support Liens and Motion to

Dismiss Notice of Writ of Withholding or in the Alternative Motion for Leave to File a Motion to

Stay Issuance of Writ of Withholding, and Patricia Holmes’ Second Amended Intervention To

Resolve Interest in Property Subject To Child Support Liens.

All matters of law and fact were submitted to the Court. The Court finds it has

jurisdiction of the partim and the subject matter of this case. All persons entitled to notice were

0'i"_6

1 L properly notified. A record of testimony was made, £5, 33 h Page IT IS ORDERED that Amy William is granted and rendered a judgment for child-

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support arrearagcs, including accrued interest against Harold F. Holmes in the amount of 4277823l

3 1-19,’, ‘fall. 70 as of fl/Ni I9’. 31 0 D9 , the date ofrcndition ofthis judgment, such

6 percent simple interest per year until the date the judgment Number:

judgment bearing interest at is paid,

Document andisrcndcrodon 30191. IQ, Q0133 .

Pagclnffi

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Cettified

Attorney's Fees

IT IS ORDERED that ajudgment for attomey's fees of$ ,5’ 00 0. 01) are taxed

as costs against Harold F. Holmes, and Harold F. Holmes is ORDERED to pay those fees, by cash, cashier's check, or money order, directly to Steven A. Sinkin & Karen L. Marvel, at Sinldn & Man/el, 105 West Woodlawn, San Antonio, Texas 78212 and Shawn Casey, PO. Box

27247, Houston, Texas 77227. The attorney may enforce this order for fees in the attorney's

own name and such judgment bearing interest at the maximum rate provided by law fiom the

date this order is rendered until paid.

In the event of an unsuccessful appeal (direct or indirect) to the Court of Appeals by

Harold F. Holmes an additional judgment of S -

Q’ for attomcy’s fees is granted

in favor of Steven A. Sinkin & Karen L. Marvel and Sinkin & Marvel and Shawn Casey and against Harold F. Holmes. In the event of mi unsuccessful petition for review or indirect appeal

to the Supreme Court of Texas by Harold F. Holmes an additional judgment of

S ‘jl 2

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for attomey’s fees is granted in favor of Steven A. Sinkin & Karen L.

Marvel and Sinkin & Marvel and Shawn Casey and against Harold F. Holmes. In the event the

petition for review or indirect appeal to the Supreme Court of Texas by Harold F. Holmes is

granted and ultimately unsuccessful, an additional judgment of S ~ Q ' for

attomcy’s fees is granted in favor of Steven A. Sinkin & Karen L. Marvel and Sinkin & of6

2 Marvel and Shawn Casey and against Harold F. Holmes. In the event of the filing of a petition Page

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for bankruptcy by Harold F. Holmes an additional judgment of S -Q ‘ for

42778231

attomey‘s fees is granted in favor of Steven A. Sinkln & Karen L. Marvel and Sinkin & Marvel Number:

and Shawn Casey and against Harold F. Holmes for the collection of child support. The

attorney may enforce this judgment for fees in the attorney's own name and such judgment Document

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Certified

bearing interest at the maximum rate provided by law from the date this order is rendered until

paid.

IT IS (3RDERED that Amy Williams is granted and rendered a judgment for court costs of$ - against Harold F. Holmes. Such judgment for court costs bearing interest at

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the maximum rate provided by law from the date this order is rendered until paid.

IT IS ORDERED Amy Williams is entitled to issue child support liens, lcvics, and

writs of income withholding as remedies for the collection of unpaid child support. ltlfi

su evy,

Ordcrfar Mthhalding

IT IS ORDERED that in addition to all other remedies available to enforce the ,

\spn~m'h‘s£5B #1-.eTE-)d4$Fi9M1L7Gx_@

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arrcarages enumerated above shall be payablqihrough ajudici writ of withholding from

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by the Texas Family Code. lTI _

earnings for child suppo

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FURTHER ORDERED that diejudicial writ of withholding from earnings for child support shall be binding on Harold F. Ilolmes's present employer and all subsequent employers.

IT IS ORDERED that all child support payments be made to:

Texas Child Support

of6 State Disbursement Unit 3 PO. Box 659791 Page San Antonio, TX 78265-9791 -

IT IS ORDERED that Harold F. Holmcs's address for service is 9902 Towne Tower Lanc, 427'/823l

Sugar Land, Texas 77478. I'l' IS FURTHER ORDERED that Harold F. Holmes shall notify in & Marvel at

Number:

writing this Court Sinkin 105 West Woodlawn, San Antonio, Texas 78212-3457,

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Certified

telccopier (2 1 0)73 6-2777, and the State Case Registry within seven (7) days of any change in address

or employment.

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IT IS ORDERED th t all relief not granted herein is denied.

Signed this Date:

ELMUZ/,0

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Hon. Frank Rynd, Judge Presiding

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42778231

Number:

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Certified

Approved as to Form & Substance: Law Officcs of Sinkin & Barretto, P.L.L.C. 105 West Woodlawn San Antonio, Texas 78212-3457 (210) 732-6000 Telephone (210) 736-2777 Tclccopicr

By:

Steven A. Sinkin State Bar No. 18438700 Karen L. Marvel State Bar N04 13144910

&

Shawn Casey Associates P.O. Box 27247 Houston, TX 77227 (713) 823-5065 Telephone

Br

Shawn Casey State Bar No. 03960500

Attorneys for Amy Williams, Sinkin & Barretto, P.L.L.C., and Karen Marvel

Joseph lndelicato, Jr., P.C. 5291 Dolores Houston, Texas 77057 (713) 952-1 1 15 Telephone (713) 532-2949 Telecopier

OH:

By:

5 Joseph Indelicato, Jr. Page State Bar No.10389400

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Attorneys for Harold Holmes and 42778231 Patricia Holmes

Number:

Document

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Certified

Mr. Randy Boykin Assistant Attorney General Houston OAG SW Unit 0607E Office of the Attorney General, Child Support Division 6200 Savoy, Suite 930 Houston, TX 77036

By:

Randy Boykin, AAG

Harold F. Holmes

Patricia Holmes

Amy Williams

£)f6

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42778231

Number:

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Certified

I,Chris Daniel, District Clerk of Harris County, Texas certify that this is a true and correct copy of the original record filed and or recorded in my office, electronically or hard copy, as it appears on this date. Witness my official hand and seal of office this August 13, 2015

Certified Document Number: 42778231 Total Pages: 6

fléflwz DISTRICT CLERK Chris Daniel, HARRIS COUNTY, TEXAS

In accordance with Texas Government Code 406.013 electronically transmitted authenticated documents are valid. If there is a question regarding the validity of this document and or seal please e-mail support@hcdistrictclerk.com

No.

IN THE INTEREST or §

GLENNA NOEL HOLMES E

MINOR CHILD 3 HARRIS COUNTY, TEXAS

MOTION TO MODIFY. CORRECT, OR REFORM JUDGMENT

HAROLD HOLMES moves this Court to modify, correct, or reform the judgment

19, 2009, the above-styled and numbered cause, and in support of this motion shows: 0&

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HAROLD HOLMES requests this Motion to Modify, Correct, or Refonn Judgment for the

following reasons: (1) Determining the amount of monthly payment of arrearages allowed to be withheld

from Mr. Ho|mes's earnings; and (2) Calculating the proper amount of interest, if any, on child support

arrearages.

I. Order of Withholding

Since the Court signed the judgment, AMY WILLIAMS has already issued and served six notices

of child support liens to financial institutions and garnished $524.20 from HAROLD HOLMES's latest pay

check. AMY WILLIAMS. through her attorney of record, has issued a Judicial Writ of Income

Withholding to Employer ordering HAROLD HOLMES‘s employer to withhold $2,311.95 per month for

child support arrearages. A true and correct copy of the Judicial Writ of income Withholding to

of‘)

Employer is attached hereto and incorporated by reference as Exhibit A. The amount withheld from Mr‘ 1 Page Holmes latest paycheck was 50 percent of his paycheck.

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42854526 HAROLD HOLMES requests this Court modify, correct, or reform the judgment in this cause to

show that AMY WILLIAMS is not entitled to child support arrearages, as Mr. Holmes paid child support Number:

directly to her, per their agreement until the child was eighteen years old, in an amount above the court

Document ordered child support. In the alternative, HAROLD HOLMES requests this Court modify, correct, or reform

EXHIBIT

A

Certified y 3

B

the judgment in this cause to show that AMY WILLIAMS shall be authorized to withhold $150.00 per month

from HAROLD i-l0LMES’s wages for the child support arrearages, or in the alternative, no more than the

specific monthly amount the Court finds appropriate to collect on the judgment on arrears. HAROLD

HOLMES further requests this Court to terminate the Judicial Writ of Income Withholding to Employer,

attached as Exhibit A, and sign a wage withholding order that reflects the specific monthly amount the

Court orders to be withheld.

Although Section 158.009 of the Texas Family Code states that an obligor may withhold earnings

up to a maximum amount of 50 percent, there is no minimum amount required to withhold to collect child

support arrearages and the Court may order the monthly amount to be withheld. In re Chambers, 5 S,W.3d

341 (Tex. App.—San Antonio 1999, no pet); In re D.C.. 180 S.W.3d 647 (Tex. App.—Waco, 2005, no pet.);

and In the Interest M. CR, 55 SW3d 104(Tex. App.4an Antonio, 2001, no pet).

As stated in the opinion of in the Interest of M.C.R.. "[t]he trial court is accorded broad discretion in

setting and modifying child support payments. See in re Davis, 30 S.W.3d 609, 616 (Tex. App.——

Texarkana 2000, no pet.). The trial court retains discretion in many other areas concerning child support.

For example, the court may exercise discretion in determining the amount of monthly payment of

arrearages once the total amount is confirmed, see Starch v. Nelson, 878 S.W.2d 302, 308 (Tex. App.~

Corpus Christi 1994, no writ); Tamez v. Tamez, 822 S.W.2d 688. 692 (Tex. App.—Corpus Christi 1991, writ

of9 denied); and in determining whether to extend the repayment schedule for a reasonable length of time 2 Page upon a showing of unreasonable hardship on the part of the obligor...“ in the interest M. CR, 55 SW3d App.—San

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104, 109 (Tex. Antonio, 2001, no pet).

42354526

The current withholding order, taking fitty percent of Mr. Holmes’s earnings. imposes a severe

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hardship on him unless the wage withholding order is modified.

Document

Certified

HAROLD HOLMES requests this Court modify, correct, or reform the judgment in this cause to

show that AMY WILLIAMS is not entitled to withhold from his eamlngs, or, in the alternative, that the

amount of monthly withholdings be limited to a specific amount each month that does not impose

unreasonable hardship upon him. HAROLD HOLMES further requests this Court to terminate the Judicial

Writ of Income Vlfirhholding to Employer, attached as Exhibit A.

II. Interest

HAROLD HOLMES does not owe any interest for child support arrearages because he has in tact

paid his child support obligation, in full, to AMY WILLIAMS. As such, HAROLD HOLMES requests that the

Court modify, correct, or reform the judgment by stating no interest is owed.

in the alternative. if the Court finds that interest is owed, HAROLD HOLMES requests that the

Court recalculate the interest. First, the Court should only calculate the interest that AMY WILLIAMS would have been entitled to had she brought a child support action within the timetrame allowed by law,

i.e., calculate interest through 1993.

In the alternative, if the Court finds that interest is owed through 2009, HAROLD HOLMES

requests the Court recalculate the interest based upon the incorrect computation of the child support

arrearages and the interest on the child support arrearages, as stated in Amy Williams’ Exhibit 6. including

but not limited to the incorrect amounts of child support stated for years 1972 and 1977.

In the allemative, HAROLD HOLMES requests the Court recalculate the interest by not computing of9

3 interest on principal that has not been previously confirmed and reduced to money judgment. Page

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in the alternative, HAROLD HOLMES requests the Court recalculate the interest by not computing

prejudgmenl

42854526

interest.

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Certified

I/I. Prayer

HAROLD HOLMES prays that this Court modify, correct, or reform the judgment as stated herein.

HAROLD HOLMES prays for general relief.

Respectfully submitted.

THE WADDELL LAW FIRM, P.C.

917 525

Franklin, Suite

Houston, Texas 77002 Tel: (832) 239-8590 Fax: (713) 228-2297-2949 ATTORNEY FOR HAROLD HOLMES

NOTICE OF HEARING

The above motion is set for hearing on

Judicial District Court, Harris County, Texas.

AUG

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2 % at ‘E M. in 309"‘

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Judge or Clerk

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Certified

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the above was forwarded via facsimile, and/or

certified mail in accordance with the Texas Rules of Civil Procedure on this the 17th day of July, 2009, to

the following:

Steven A. Sinkin Karen L. Marvel 105 West Woodlawn San Antonio, Texas 78212-3457 (210) 732-6000 (fax)

Randy Boykin Sue Tomlinson Office of the Attorney General 6200 Savoy. Suite 930 Houston, Texas 77036 (713) 785-3452 (fax)

ure E. Atto ey for Harold Holmes

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In the Dlstrict Court

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Iu the Interest of § §

309"‘ Judicial District

Glenna Noel Holmes § § .

A Child § Harris County, Texas

Judicial Writ of Income Wlthh oldlng to Employer

You, the employer of Harold F. Holmes are directed to withhold income from the Obligofs disposable earnings from this employment as follows:

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Obligor: Harold F. Holmes Obligcez Amy Williams SSN: -

46_O-82-3436 .

Address:

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9902 Town: Tower Laue -

Unisys

Sugaz-land, Texas 77478

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Employer(or any current or subsequent employer in possession of this writ):

Ali cf Independent School District Arm: Tcrcsa Ashton

Human Rusounces

PO. Box 68 A1iefTX 7741 1

Children and Dates of Birth Glenna Noel Holmes 12/23/65

Qeter[n,|'nation of A:-rang:

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6 finding Harold F. Holmes On Inna 19, 2009. the couxt iusued an Order on Chxmnlative Judgment be in antcaxs for the. amount of $55,486.78 as of_June 19, 2009.

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used in this Writ, theltxm "Arrearagc" means:

. 1. pariodic payments on lump sum child support whether past due or not, or 2. periodic ‘payments of pest due regular and/or medical child support

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EXHIBIT

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(17/15/2009 11:23 FAX 2814911924 HAL HOLMES 00::

All payments shall be made payable to Amy Williams and Child Support- 2 Collect, Inc, and shall identify the obligor, the Obligee, the date of withholding and cause number, which is

000703074.

Nogg of Qhange of Emgloygent: An employer is to notify the Court and the LAW OFFICES OF SINKIN & MARVEL within 7 days of the date that the Oblignr terminates employment. The employer must provide the

0bligor's last known address and the name and address of the 0bllgor's new employer, if known.

Referc to the Incomewlth ldlu La :

Attached to Writ is a copy of Texas Family Code, Chapter 158, which sets forth rights, duties this

and potential liabilities ofemploycrs, in additionto the provisions of this WriL

Issued on this dune: Hm 9 mm :9" vlerk ef the mstrict Court ~

ii‘: (”gr*-\_€17y‘;:‘\.‘ Harris County, Texas

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o7/1s/zooa 11:23 FAX 2314911024 HAL HOIMES I2] 003 ‘

Witllhoiding Earglngvs for Child fiuppgrt:

or subsequent employer of Obligor in possession of this Writ is directed to begin

Any current

the date

withholding from Obligoi-‘s disposable. earnings no later than the firs: pay period following this Writ is served on the employer.

The amount of earnings to be withheld is:

1. $2,311.95 if Obligor is paid monthly, which is $0.00 to be applied to current support and

$2,311.95 toward the arrearage owed.

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,1. 2. $1,155.98 lfobllgor is paid twice monthly, which is $0.00 to be applied to current support and $1,155.98 toward the arrearage owed.

3.

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$1,066.96 if Obligor is paid every other week, which is $0.00 to be applied to current

support and $1,066.96 Inward the amearage owed.

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4. $533.60 if the Obligor is paid every week, which is $0.00 to be applied to current support and $533.60 toward the amsarage owed.

The employer shall withhold earnings in the above amount until youreeeive notice the total amount duehns been paid.

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l_Vl'_g_xjmum Amgpnt Withheld:

The maximum amountto be withheld shall not exceed 50 per cent of 0bl.igor's disposable earnings. 'lfmore than one order or writ is received for different children of the same Obllgor, payment should be made according to Texas Family Code Section 158.207.

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"Disposable Earnings" means thepart of the eamings ufaitindividual remaining after the deduction from those earnings of any amount required bylaw or to be withheld, union dues, non-discretionary retirement contributions, and medical, hospitalization, and disability insurance coverage for the '

qf§ Obligor and the Obligofs children.

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Method of jfgyment:

Page

The cm.p1oyes-isdirrxpsted to pay all amounts withheld on each regular pay day to;

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Texas Child Support

N1lmher:4i854§i6

State Disbursement Unit

PO. Box 659791

San Antonio, TX 7826509791 Pogez of 9

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Came to hand on the following date at the following lime’. o'clock and executed on the following date at the following time:

by delivery by certified mail, return receipt requcsted to the employernamed wi1hi.u,as herein directcd, a tme copy of this Writ together with a copy of th::Texas Family Code, Chapter 158.

This original mtumcd on the following date:

Clerk of the District Court Harris County, Texas

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Deputy

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OblIgce‘s Attorney: Law Offices of

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Sinldn & Marvel 105 West Woodlawn Ave. San Antonio, TX 78212-3457 210-732-6000 Telephone 210~73 6—2777 Telccopier

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-._

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1, Chris Daniel, District Clerk of Harris County, Texas certify that this is a true and correct copy of the original record filed and or recorded in my office, electronically or hard copy, as it appears on this date. Witness my official hand and seal of office this August 13, 2015

Certified Document Number: 42854526 Total Pages: 9

a""’°W««Jo€ DISTRICT CLERK

Chris Daniel, HARRIS COUNTY, TEXAS

In accordance with Texas Government Code 406.013 electronically transmitted authenticated documents are valid. If there is a question regarding the validity of this document and or seal please e-mail support@hcdistrictclerk.com

[g

R C (L

E “No. 703024 IN F

THE INTEREST or ,6, IN THE nrsmrcr COURT fie,

Kw M

9‘.;,\n

GLENNA NOEL HOLMES "N3 § 309TH JUDICIAL DISTRICT

A CHILD HARRIS COUNTY, TEXAS

T

xxme‘

Wu“ ((1 [) Lb {.m(_,>

8,

FINAL REFORMED ORDER

On September 18. 2009, the Court heard Amy William's Motion for Reconsideration," Alternatively

Motion for New Trial on the Issue ofAttomey's Fees and Otherwise; and Motion to Strike Pleadings. The

Court also heard Harold Ho|mes‘s Motion for New Trial for Harold Holmes; Motion to Modify, Correct, or

Reform Judgment, Motion" for Temporary Orders Pending Appeal; Motion to supersede Judgment. The

Court also heard Patricia Webber, formerly known as Patricia Ho|mes‘s Motion for Reconsideration and

I

Motion for New Trial.

All persons entitled to notice were properly notified. Amy Williams and Harold Holmes appeared in

person and through their respective counsel. Patricia Webber appeared through counsel. The State of

Texas did not appear.

A record was made by the official court reporter of the 309"‘ Judicial District Court, Delores

Johnson.

IT IS ORDERED that Amy William's ‘Motion to Strike Pleading on Harold Ho|mes's Motion tor

Reconsideration; Alternatively Amended Motion for New Trial is GRANTED as untimely, and the Court of5

1 -

proceeded to hear the Motion for New Trial by Harold Holmes filed on July 17, 2009.

Page

-

IT IS ORDERED that Amy William's Motion for Reconsideration,’ Altematively Motion tor New Trial

on the Issue of Attorney's Fees and Otherwise was granted in part, as stated herein.

4370419]

Number:

IT IS ORDERED that Harold Ho|mes's Motion for New Trial for Harold Holmes; Motion for

Temporary Orders Pending Appeal were denied.

Document

EXHIBIT

Certified

,

C

IT IS ORDERED that Harold Holmes's Motion to Modify, Correct, or Reform Judgment and Motion

to supersede Judgment were granted in part, as stated herein.

IT IS ORDERED-that Patricia Holmes‘s Motion for Reconsideration and Motion for New Trial were

denied.

IT IS ORDERED that Amy Williams is granted and rendered a judgment for child support ‘H 1"s‘h"'0

‘

arrearages, including accrued interest against Harold F. Holmes in the amount of as of T..Ml‘l

',

judgment, such judgment bearing interest at 6 percent 2009, the date of rendition of this 3’ ,, lfi

simple interest per year until IT lS 0V~.\3‘U~I-i‘) 041 the date the judgment is paid and fnqncnfx f<L<\‘v<o/C.-Hu.T-av-L 17,7001 is rendered on

:Lallt><«1r~<.o¢v't‘q9{C.'

2009.

~V4N

IT IS ORDERED hat a judgment for attomey‘s fees of $5,000.00 are taxed as cos against Haro d

F. Holmes, and Harold Holmes is ORDERED to pay those tees, by cash, cashier's check, or money order,

directly to Steven A. Sinkin & Karen L. Marvel, at Sinkin & Marvel, 105 West Woodlawn, San Antonio,

Texas 78212 and Shawn Casey, P.O. Box 27247, Houston, Texas 77227. The attorney may enforce this

order for fees in the attomey’s own name and such judgment bearing interest at the maximum rate

provided by law from the date this order is rendered until paid.

In the event of an unsuccessful appeal to the Court of Appeals by Harold F. Holmes an additional

judgment of $3,000.00 for attomey's fees is granted in favor of Steven A. Sinkin Karen L. Marvel and

Sinkin & Marvel and Shawn Casey and against Harold Holmes. in the event of an unsuccessful petition for

review to the Supreme Court of Texas by Harold Holmes an additional judgment of $2,000.00 for attorney's of5

2 fees is granted in favor of Steven A. Sinkin & Karen L.-Marvel and Sinkin & Marvel and Shawn Casey Page

-

against Harold Holmes. The attorney may enforce this judgment for fees in the attorney's own name and

4370419]

such judgment bearing interest at the maximum rate provided by law trom the date this order is rendered

until paid.

Number:

Document

Certified

to

IT IS ORDERED that Amy Williams is granted and rendered a judgment for court costs of $552.08

against Harold Holmes. Such judgment for court costs bearing interest at the maximum rate provided by

law from the date this order is rendered until paid.

IT IS ORDERED that Amy Williams is entitled to issue child support liens, levies, and writs of

income withholding as remedies forcollection of unpaid child support, and all remedies available to enforce

the child support arrearage judgment enumerated above shall be payable as permitted by the Texas Family

Code and through this Court's EmpIoyer’s Order l/Wthholding from Harold Holmes's Earnings with the

following exceptions:

a. IT lS ORDERED that the income withholding shall be limited to $800.00 per month.

b. IT IS ORDERED that Harold F. Holmes homestead, presently located at 9902 Towne Tower

Lane, Sugar Land, Texas 77478 shall be exempt from any execution for the judgment for child

support interest arrearage or the judgment for attomey’s tees and costs awarded.

c. IT IS ORDERED that Harold Holmes's 1997 Mercury Marquis motor vehicle, VlN is

2MELM75WOVX710739 shall be exempt from any execution for the judgment for child support

interest arrearage or the judgment for attomey’s fees and costs awarded.

d. IT l8 ORDERED that Harold F. Holmes checking account_at Bank of America, Account No.

of5

3 O05865690210shall be exempt from any execution for the judgment for child support interest Page

-

arrearage or the judgment for attomey’s fees and costs awarded.

43704191

IT IS FURTHER ORDERED that the Lien previously issued to Bank of America to execute on

Number:

Harold F. Holmes's Account No. 005865690210 shall be released and that no other liens may be placed on

this bank account for purposes of the judgments enumerated herein, Document

Certified

DJ

IT IS ORDERED that all child support upaymentsube made to Texas Child Support State

Disbursement Unit, P..O. Box 659791, San Antonio, Texas 78265-9791.

IT IS ORDERED that Harold F. Holmes shall notify in writing the Court, and Sinkin & Marvel at 105

West Woodlawn, San Antonio, Texas 78212-3457 telecopier (210) 736-2777, and the State Case Registry

within seven (7) days of any changes of address or employment,

~~

On this date, the Court signed an Employer's Order Vlfrthholding from Harold Holmes’s

Earnings, which complies with the Court's ruling regarding withholding from Harold F. I-lo|mes‘s income.

Date of Order

-Signed this the / 57” day of .2009.

'

/

JUDGE PRESIDING

APPROVED AS TO FORM: ‘

THE WADDELL LAW FIRM, P.C.

By:

LAUREN E. WADDELL State Bar No. 24036440

of5 917 Franklin, Suite 525 4 Houston, Texas 77002 Page (832) 239-8590 -

(713) 228-2297/Facsimile ATTORNEY FOR HAROLD HOLMES 43704191

AND PATRICIA WEBBER

Number:

Document

Certified

LAW OFFICES OF SINKIN 8: MARVEL

~ST VEN SINKIN Slate Bar No. 18438700 /(“,2 L‘::“”"/ / L1 /0

105 Westwoodiawn Avenue .

San Antonio, Texas 78212 (210) 732-6000 (210) 736-2777 (Facsimile) ATTORNEY FOR AMY WILLIAMS

OFFICE OF THE ATTORNEY GENERAL

Byi

RANDY BOYKIN -

State Bar No. 6200 Savoy, Suite 930 Houston, Texas 77036 (713) 78543452 (Facsimile) ATTORNEY GENERAL

of5

5 Page

-

4370419]

Number:

Document

Certified

I, Chris Daniel, District Clerk of Harris County, Texas certify that this is a true and correct copy of the original record filed and or recorded in my office, electronically or hard copy, as it appears on this date. Witness my official hand and seal of office this August 13, 2015

Certified Document Number: 43704191 Total Pages; 5

Ciaaflmz DISTRICT CLERK Chris Daniel, HARRIS COUNTY, TEXAS

In accordance with Texas Government Code 406.013 electronically transmitted authenticated documents are valid. If there is a question regarding the validity of this document and or seal please e-mail support@hcdistrictclerk.com

7/30/2015 3:16:18 PM

Chris Daniel —

District Clerk Harris County Envelope No. 6296607 By: Pal Montgomery

Filed: 7/30/2015 316:18 PM

INCOME WITHHOLDING FOR SUPPORT P993

[I ORIGINAL INCOME WITHHOLDING ORDERINOTICE FOR SUPPORT (IWO) RAOWX D AMENDED IWO E] ONE-TIME ORDERINOTICE FOR LUMP SUM PAYMENT TERMINATION of IWO Date; 07/30/2015

|:|ChiId Support Enforcement (CSE) Agency Court L] Attorney |:]Private individual/Entity (Check One) NOTE: This IWO must be regular on its face. Under certain circumstances you must reject this IWO and return it to the sender (see IWO instructions if you

receive this document from someone other than a State or Tribal CSE agency or a Coun, a copy of the underlying order must be attached.

StateITribefl’erritory Texas Remittance Identifier (include wlgayment) Citylcounty/Dist.f|‘ribe Harris Counlv Order ldentifier000703024 / 30 H Private IndividuaUEntity CSE Agency Case Identifier 0010679282

Aliei ISD RE: Holmes, Harold Employerllncome Vtfithholders Name Employee/Obligor's Name (Last, First, Middle)

XXX-XX-XXXX

Employerllncome Vlnthholders Address Employee/Obllgors Social Security Number PO. Box 68 Vllilliams. Amy Custodial PartyIOb|igee’s Name (Last, First, Middle)

Alief, Texas 77411

Employerllncome Vifithholdefs FEIN

Chi|d(ren)'s Name(s) (Last, First, Middle) Child(ren)‘s Birth Date(s) Holmes, Glenna Noel 12/23/1955

ORDER INFORMATION: This document is based on the support or withholding order from Texas (Statefi'ribe). You are required by law to deduct these amounts from the employee/obIigor’s income until further notice.

15

0 Per month current child support $ 0 Per month past-due child support - Arrears greater than 12 weeks? CIYesI:] No $ 0 Per month current cash medical support $ 0 Ferment“ past-due cash medical support $ 0 Per month current spousal support $ 0 Perrnenth past-due spousal suppon 0f3 5 0 per month other (must specify) past-due child suppon obligation temporarily suspended until October 2, 2015 ,

I for Amount to Wlthhoid of S a Total 0 per month Page AMOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the Order Information. if

-

your pay cycle does not match the ordered payment cycle, withhold one of the following amounts:

Oper weekly pay period $ 0 per semimonthly pay period (twice a month)

$

0per biweekly pay period (every two weeks)$ 0 per monthly pay period $

Lump Sum Payment: Do not stop any existing IWO unless you receive a termination order.

66465545

$

REMITTANCE INFORMATION: If the employeelobligors principal place of employment is “X35 (statefiribe), you must begin withholding no later than the firs! pay period that occurs -——-days after the date of Send _

Number:

receipt .

payment within Same working days of the pay date. if you cannot withhold the full amount of support for any or all orders for this employeelobligor, withhold up to 50 % of disposable income for all orders. If the employeelobligors principal place of employment is not Texas (StateITribe), obtain withholding limitations, time requirements, and any n -.9 n for the Document '

allowable employer fees at n r I '

employee/obligors principal place of employmnt.

Certified Document Tracking identifier EXHIBIT OMB 0970-0154

D

For electronic payment requirements and centralized payment collection and disbursement facility information (State ‘

Disbursement Unit [SDU]). see u I '

. . , .

include the Remittance identifier with the payment and if necessary this FIPS code:

Remit gayment to Texas Child Support Disbursement Unit (TXCSDU) (SDUlTribal Order Payee) at PO. ox 659791.53" Antonio. Texas 78265-9791 (SDU/'l'ribal Payee Address) El Return to Sender [Completed by Empioyerllncome Withholder]. Payment must be directed to an SDU in accordance with 42 USC §666(b)(5) and (b)(6) or Tribal Payee (see Payments to SDU below). if payment is not directed to an SDUITribal Payee or this IWO is not regular on its face, you must check this box and return the IWO to the sender.

Signature of Judgelissuing Official (if regiiiired by State or Tribal law): Print Name otJudge/issuing gfficiaelzd -7), /_, J

N

T

TitieofJudgellssuing Official. '9” "iW”’{i’iU - V

Date of Signature: 7/31/207 5 V "

if the employeelobligor works in a State or for a Tribe that is different from the State or Tribe that issued this order, a copy of this IWO must be provided to the employeelobligor. E] it checked, the employer/income withhoider must provide a copy of this form to the employeelobligor.

ADDlTiONAL INFORMATION FOR EMPLOYERSIINCOME WITHHOLDERS State-speclflc contact and withholding information can be found on the Federal Employer Services website located at:

'

r I i I l rl n I n

Priority: Vimhhoiding for support has priority over any other legal process under State law against the same income (USC 42 §666(b)(7)). lfa Federal tax levy is in effect, please notify the sender. Combining Payments: When remitting payments to an SDU or Tribal CSE agency, you may combine withheld amounts from more than one employee/obIigor's income in a single payment. You must, however, separately identify each employee/obiigor's portion of the payment.

Payments To SDU: You must send child support payments payable by income withholding to the appropriate SDU or to a Tribal CSE agency. If this [W0 instructs you to send a payment to an entity other than an SDU (e.g., payable to the custodial party, court, or attorney), you must check the box above and return this notice to the sender. Exception: If this

iWO was sent by a Court, Attorney. or Private |ndividualIEntity and the initial order was entered before January 1, 1994 or the order was issued by a Tribal CSE agency, you must follow the "Remit payment to‘ instructions on this form.

Reporting the Pay Date: You must report the pay date when sending the payment. The pay date is the date on which the amount was withheld from the employee/obligor's wages. You must comply with the law of the State (or Tribal law if applicable) of the employeelobiigors principal place of employment regarding time periods within which you must implement the withholding and fonivard the support payments. Multiple lWOs: if more than one IWO against this employeelobligor and you are unable to fully honor all lWOs there is

due to Federal, State, or Tribal withholding limits, you must honor all iWOs to the greatest extent possible, giving priority of3 to current support before payment of any past-due support. Follow the State or Tribal law/procedure of the employee! obIigor's principal place of employment to determine the appropriate allocation method.

2 Page Lump Sum Payments: You may be required to notify a State or Tribal CSE agency of upcoming lump sum payments to this employeelobligor such as bonuses, commissions. or severance pay. Contact the sender to determine if you are required to report andlor withhold lump sum payments, -

66465545 Liability: you have any doubts about the validity oi this IWO, contact the sender. if you fail to withhold income from the if

empioyeelobiigofs income as the lWO directs, you are liable for both the accumulated amount you should have withheld and any penalties set by State or Tribal law/procedure.

Number:

Antl—dlscriminatIon: You are subject to a fine determined under State or Tribal law for discharging an employeelobligor from employment, refusing to employ, or taking disciplinary action against an employeelobligor because of this IWO.

Document

OMB Btpiration Date— 05/31/2014. The OMB Expiration Date has no bearing on the tennination date oithe IWO; it identifies the version of Certified

the form currently in use.

Employefs Name: Niel 150 Employer FEIN: Employee/Ob|igor‘s Name: Harold Holmes CSE Agency Case Identifier: 0010579232 Order Identifier: 000703024

Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673(b)): or 2) the amounts allowed by the State or Tribe of the empioyeel obligors principal place of employment (see REMITTANCE INFORMATION). Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; statutory pension contributions; and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family. However, those limits increase 5% - to 55% and 65% - it the arrears are greater than 12 weeks. If permitted by the State or Tribe, you may deduct a fee for administrative costs. The combined support amount and fee may not exceed the limit indicated in this section.

For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employersfincome withholders who receive a State IWO, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employer/income withholder is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)).

Depending upon applicable State or Tribal law, you may need to also consider the amounts paid for health care premiums in detennining disposable income and applying appropriate withholding limits.

Arrears greater than 12 weeks? if the Order Information does not indicate that the arrears are greater than 12 weeks, then the Employer should calculate the CCPA limit using the lower percentage.

Additional Information:

NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUS: if this employee/obligor never worked for you you are no longer withholding income for this employee/obligor. an employer must promptly or notify the CSE agency and/or the sender by returning this form to the address listed in the Contact Information below:

C] This person has never worked for this employer nor received periodic income.

I] This person no longer works for this employer nor receives periodic income. Please provide the following information for the employeelobligorz

Termination date: Last known phone number:

Last known address:

Final payment date to SDU/ Tribal Payee: Final payment amount:

New employers name: New employers address:

of3

3 CONTACT INFORMATION: Page

-

'

If you have any questions, contact 30901 D'5'i'¢l 90"” (Issuer name)

by phone at(713) 2744520 , by fax at , by email or website at: .

66465545

Send terminationlincome status notice and other correspondence to: 201 Caroline, 16th Floor, Houston, Texas 77002 (Issuer address).

Number: -

it the employee/obligor has questions, contact 309"‘ District C00" (Issuer name)

by phone at(713) 2744520 ,by fax at by email or website at ,

-

Document

IMPORTANT: The person completing this form is advised that the information may be shared with the employee/obligor.

Certified 1, Chris Daniel, District Clerk of Harris County, Texas certify that this is a true and correct copy of the original record filed and or recorded in my office, electronically or hard copy, as it appears on this date. Witness my official hand and seal of office this August 13, 2015

Certified Document Number: 66465545 Total Pages; 3

flzflwz DISTRICT CLERK Chris Daniel, HARRIS COUNTY, TEXAS

In accordance with Texas Government Code 406.013 electronically transmitted authenticated documents are valid. If there is a question regarding the validity of this document and or seal please e-mail support@hcdistrictclerk.com

7/30/2015 3:16.18 PM

Chris Daniel -

District Clerk Harris County Envelope No. 6296607

By: Pat Montgomery

Filed: 7/30/2015 31P6.18 PM INCOME WITHHOLDING FOR SUPPORT 993

El ORIGINAL INCOME WITHHOLDING ORDERINOTICE FOR SUPPORT (IWO)

AOWOX

I2 AMENDED IWO El ONE-TIME ORDERINOTICE FOR LUMP SUM PAYMENT El TERMINATION of [W0 Date: 10/02/2015

[:]Child Support Enforcement (CSE) Agency [2] Court |:| (Check One)

Attorney |:]Private IndividuaIIEntity NOTE: This IWO must be regular on its face. Under certain circumstances you must reject this IWO and return it to the sender (see two instructions n u it you ' ' '

'

.

receive this document from someone othe than State or ribal CSE agencyor a Court. a copyof the unerlying order must be attached.

State/TribeITerritory Te><a3 Remittance identifier (inciu ew ent) City/CountyIDist.iTribe Hams Counly Order identifier000703024 7 355%? Private Individual/Entity CSE Agency Case Identifier 0010675282

Aiie1lSD RE; Holmes. Harold Empioyerlinoome V\fithho|der's Name Employee/Obligofs Name (Last, First, Middle)

XXX-XX-XXXX

Employerllncome \Nithholders Address Employee/Obiigors Social Security Number P.O. Box 68 Vlfllllams, Amy Custodial Party/Obiigee's Name (Last, First, Middle)

Aliet. Texas 77411

Empioyerllnoome V\fithhoider’s FEIN

Child(ren)'s Name(s) (Last, First, Middle) ChiId(ren)‘s Birth Datets) Holmes, Glenna Noel 12/23/1965

ORDER INFORMATION: This document is based on the support or withholding order trom Texas (State/'i'ribe). You are required by law to deduct these amounts from the employee/obiigofs income until further notice.

Per current child support Per past-due child support - Arrears greater than 12 weeks? l:]Yes[:] No Per current cash medical support €fl€fl$$€fl39€fl

Per past-due cash medical support Per current spousal support Per past-due spousal support 800.00 Per month other (must specify) past-due child support reinstated October 2, 2015 0f3

i for a Total Amount to Wlthhold of $ 800.00 per month Page

AMOUNTS TO WITHHOLD: You do not have to vary your pay cycle to be in compliance with the Order Information. if

your pay cycle does not match the ordered payment cycle, withhold one of the following amounts:

—

134-52per weekly pay period $ 4°‘?-9° per semimonthly pay period (twice a month)

$

66465652

$ 359-23per biweekly pay period (every two weeks)$ 800.00 per monthly pay period $ Lump sum Payment: Do not stop any existing lWO unless you receive a termination order.

REMITTANCE INFORMATION: if the empioyeelobligofs principal place of employment is “X35 (Stateffnbe).

Number:

you must begin withholding no later than the first pay period that occurs ——- days after the date of receipt Send .

payment within Same working days of the pay date. if you cannot withhold the full amount of support for any or all orders forthis employee/obligor, withhold up to 50 % of disposable income for all orders. If the employee/obiigor‘s principal place of employment is not Texas (State/Tribe), obtain withholding limitations, time requirements, and any allowable employerfeesat nu AI - -us - ~ .~~~ n...- . uforthe Document

.. . .. ..n ~

- 1- -I .- ~~ ~

..

empioyeelobiigors principal place of employment.

Certified Document Tracking Identifier H B N OMB 0970-0154

E

For electronic payment requirements and centralized payment collection and disbursement facility information (State Disbursement Unit[SDU]), see u I An...

’

'

—. . . . , _ .. .

include the Remittance Identiflerwith the payment and if necessary this FIPS code:

Remit ay.-.-.9,-.3 :3 Texas Child Support Disbursement Unit (TXCSDU) (SDU/Tribal Order Payee) at PO. ox 659791, San Antonio. Texas 78265-9791 (SDU/Tribal Payee Address)

C] Return to Sender [Completed by Employerllncome Wlthholder]. Payment must be directed to an SDU in accordance with 42 USC §666(b)(5) and (b)(6) or Tribal Payee (see Payments to SDU below). If payment is not directed to an SDU/Tribal Payee or this lWO is not regular on its face, you must check this box and retum the IWO to the sender.

Signature of Judge/Issuing Official (if req ired by St te or Tribal law): Print Name of Judgellssuing , /,, flM/,,,,,,,,,,,,/ "‘

Title of Judge/issuing Offic' “””‘”l”V,f‘ '

[0

I

l

20 5

/l

Date of Signature: 3 V

If the employeelobligor works in a State or for a Tribe that is different from the State or Tribe that issued this order, a copy of this IWO must be provided to the employeelobligor. |'_‘] it checked, the employerfincome withholder must provide a copy of this form to the employeelobligor.

ADDITIONAL INFORMATION FOR EMPLOYERSIINCOME WITHHOLDERS

Priority: Withholding for support has priority over any other legal process under State law against the same income (USC 42 §666(b)(7)). if a Federal tax levy is in effect, please notify the sender.

Combining Payments: When remitting payments to an SDU or Tribal CSE agency, you may combine withheld amounts from more than one employee/obligor‘s income in a single payment. You must, however, separately identify each employeelobligors portion of the payment.

Payments To SDU: You must send child support payments payable by income withholding to the appropriate SDU or to a Tribal CSE agency. If this lW0 instructs you to send a payment to an entity other than an (e.g., payable to the SDU custodial party, court, or attorney), you must check the box above and return this notice to the sender. Exception: If this IWO was sent by a Court, Attorney, or Private individual/Entity and the initial order was entered before January 1, 1994 or the order was issued by a Tribal CSE agency, you must follow the "Remit payment to" instructions on this form.

Reporting the Pay Date: You must report the pay date when sending the payment. The pay date is the date on which the amount was withheld from the employeelob|igor's wages. You must comply with the law of the State (or Tribal law if applicable) of the employeelobligors principal place of employment regarding time periods within which you must implement the withholding and forward the support payments. Multiple lW0s: If there is more than one lWO against this employeelobligor and you are unable to fully honor all IWOs

due to Federal, State, or Tribal withholding limits, you must honor all lWOs to the greatest extent possible, giving priority of3 to current support before payment of any past—due support. Follow the State or Tribal law/procedure of the employee/ obligor's principal place of employment to determine the appropriate allocation method.

2 Page Lump Sum Payments: You may be required to notify a State or Tribal CSE agency of upcoming lump sum payments to -

this employeelobligor such as bonuses, commissions, or severance pay. Contact the sender to determine if you are required to report and/or withhold lump sum payments.

Liability: if you have any doubts about the validity of this IWO, contact the sender. if you fail to withhold income from the 66465652

employee/obligors income as the IWO directs, you are liable for both the accumulated amount you should have withheld and any penalties set by State or Tribal lawlprocedure.

Number:

Antl~discrlmlnatlon: You are subject to a fine determined under State or Tribal law for discharging an employeelobligor from employment, refusing to employ, or taking disciplinary action against an employeelobligor because of this IWO.

Document

OMB Expiration Date - 05/31/2014. The OMB Expiration Date has no bearing on the termination date of the lWO; it identifies the version of the fonn currently in use.

Certified

Employers Name: Nief 130 Employer FEIN: Employeelobligofs Name: Harold Holmes CSE Agency Case Identifier: 0010579252 Order Identifier: 000703024

Withholding Limits: You may not withhold more than the lesser of: 1) the amounts allowed by the Federal Consumer Credit Protection Act (CCPA) (15 U.S.C. 1673(b)); or 2) the amounts allowed by the State or Tribe of the employee! cbligor's principal place of employment (see REMITTANCE INFORMATIOAI). Disposable income is the net income left after making mandatory deductions such as: State, Federal, local taxes; Social Security taxes; statutory pension contributions; and Medicare taxes. The Federal limit is 50% of the disposable income if the obligor is supporting another family and 60% of the disposable income if the obligor is not supporting another family. However, those limits increase 5% - to 55% and 65% - it the arrears are greater than 12 weeks. if permitted by the State or Tribe, you may deduct a fee

for administrative costs. The combined support amount and fee may not exceed the limit indicated in this section.

For Tribal orders, you may not withhold more than the amounts allowed under the law of the issuing Tribe. For Tribal employersrincome withholders who receive a State IWO, you may not withhold more than the lesser of the limit set by the law of the jurisdiction in which the employerfincome withholder is located or the maximum amount permitted under section 303(d) of the CCPA (15 U.S.C. 1673 (b)). Depending upon applicable State or Tribal law, you may need to also consider the amounts paid for health care premiums In determining disposable income and applying appropriate withholding limits.

Arrears greater than 12 weeks? if the Order Information does not indicate that the arrears are greater than 12 weeks, then the Employer should calculate the CCPA limit using the lower percentage,

Additional lnfonnation:

NOTIFICATION OF EMPLOYMENT TERMINATION OR INCOME STATUS: If this employeelobiigor never worked for you or you are no longer withholding income for this employeelobligor, an employer must promptly notity the CSE agency andlor the sender by returning this form to the address listed in the Contact information below:

[I This person has never worked for this employer nor received periodic income.

[I This person no longer works for this employer nor receives periodic income. Please provide the following information for the employee/obligor:

Termination date: Last known phone number: Last known address:

Final payment date to SDUI Tribal Payee: Final payment amount:

New employers name:

a .7 New employers address:

of

3 CONTACT INFORMATION: Page

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If you have any questions, contact 309"‘ DiS"i°1 C00” (issuer name)

by phone a{(713) 274-4520 , by fax at by email or website at:

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Send terminationlincome status notice and other correspondence 66465652

to:

201 Caroline. 16th Floor, Houston, Texas 77002 (Issuer address).

Number:

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If the employeelobligor has questions, contact 3091?! District Court (issuer name)

by phone at(71:i) 274-4520 ,by fax at by email or we , site at <

Document

IMPORTANT: The person completing this fonn is advised that the information may be shared with the employee/obligor.

Certified 1,Chris Daniel, District Clerk of Harris County, Texas certify that this is a true and correct copy of the original record filed and or recorded in my office, electronically or hard copy, as it appears on this date. Witness my official hand and seal of office this August 13, 21215

Certified Document Number: 66465652 Total Pages: 3

C7/4/4«~?=W«¢€ DISTRICT CLERK

Chris Daniel, HARRIS COUNTY, TEXAS

In accordance with Texas Government Code 406.013 electronically transmitted authenticated documents are valid. If there is a question regarding the validity of this document and or seal please e-mail support@hcdistrictclerk.com

Office of the Attorney General Texas Child Support Disbursement Unit Payment Record This payment record reflects Non—CustodiaI Parent payments received by the Texas Child Support Disbursement Unit and payments received or recorded prior to the establishment of the Texas Child Support Disbursement Unit.

You may need to contact the local child support registry of the County that issued the order to ensure a complete payment record is obtained for the specified Case/Cause numbers, if the Office of the Attorney General was not the Non-Custodial Parent's payment registry before the Texas Child Support Disbursement Unit began

This payment record was generated 08/13/2015 Total Paid: 53,781.85 Names: HAROLD HOLMES (NCP) , AMY WILLIAMS (CP)

Cause Number 703024

Payment Date Payment Amount Cause ID (MM/DD/YYYY) 07/31/2015 400.00 703024 07/16/2015 400.00 703024 07/01/2015 400.00 703024 06/16/2015 400.00 703024 06/01/2015 400.00 703024 05/18/2015 400.00 703024 05/01/2015 400.00 703024 04/16/2015 400.00 703024 04/01/2015 400.00 703024 03/09/2015 400.00 703024 03/02/2015 400.00 703024 02/17/2015 400.00 703024 02/02/2015 400.00 703024 01/16/2015 400.00 703024 12/22/2014 400.00 703024 12/16/2014 400.00 703024 11/24/2014 400.00 703024 11/17/2014 400.00 703024 11/03/2014 400.00 703024 10/16/2014 400.00 703024

Thisis a true and correct copy of the computerized official child support payment records of the Texas Child Support Disbursement Unit.

This payment record is admissible in a court proceeding as evidence of payments made through the Texas Child Support Disbursement Unit pursuant to Texas Family Code Section 157.002(b)(3), Section 157.162 c~ and Section 234.001(d).

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Page 1 of 7

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EXHIBIT ~~

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Office of the Attorney General Texas Child Support Disbursement Unit Payment Record Payment Date Payment Amount Cause ID (MM/DD/YYYY) 10/01/2014 400.00 703024 09/16/2014 400.00 703024 09/02/2014 400.00 703024 08/18/2014 400.00 703024 08/01/2014 400.00 703024 07/16/2014 400.00 703024 07/01/2014 400.00 703024 06/13/2014 400.00 703024 06/02/2014 400.00 703024 05/16/2014 325.06 703024 05/01/2014 356.03 703024 04/16/2014 357.44 703024 04/01/2014 389.57 703024 03/10/2014 400.00 703024 03/03/2014 347.00 703024 02/18/2014 376.68 703024 02/03/2014 400.00 703024 01/16/2014 400.00 703024 12/23/2013 400.00 703024 12/16/2013 400.00 703024 11/25/2013 400.00 703024 11/18/2013 400.00 703024 11/01/2013 400.00 703024 10/16/2013 400.00 703024 10/01/2013 400.00 703024 09/16/2013 400.00 703024 09/03/2013 400.00 703024 08/16/2013 400.00 703024 08/01/2013 400.00 703024 07/16/2013 400.00 703024 06/28/2013 400.00 703024 06/14/2013 400.00 703024

Thisis a true and correct copy of the computerized official child support payment records of the Texas Child Support Disbursement Unit.

This payment record is admissible in a court proceeding as evidence of payments made through the Texas Child Support Disbursement Unit pursuant to Texas Family Code Section 157.002(b)(3), Section 157.162(c), and Section 234.001(d).

Page 2 of 7

Office of the Attorney General Texas Child Support Disbursement Unit Payment Record Payment Date Payment Amount Cause ID (MM/DD/YYYY) 06/03/2013 400.00 703024 05/16/2013 400.00 703024 05/01/2013 400.00 703024 04/16/2013 400.00 703024 03/29/2013 400.00 703024 03/11/2013 400.00 703024 03/01/2013 400.00 703024 02/19/2013 400.00 703024 02/01/2013 378.10 703024 01/16/2013 400.00 703024 12/26/2012 400.00 703024 12/17/2012 400.00 703024 12/03/2012 400.00 703024 11/16/2012 400.00 703024 11/01/2012 400.00 703024 10/16/2012 400.00 703024 10/01/2012 400.00 703024 09/17/2012 400.00 703024 09/04/2012 321.54 703024 08/16/2012 400.00 703024 08/01/2012 400.00 703024 07/13/2012 400.00 703024 06/29/2012 400.00 703024 06/15/2012 400.00 703024 06/01/2012 400.00 703024 05/16/2012 400.00 703024 05/01/2012 400.00 703024 04/16/2012 400.00 703024 04/02/2012 400.00 703024 03/12/2012 400.00 703024 03/01/2012 400.00 703024 02/16/2012 400.00 703024

Thisis a true and correct copy of the computerized official child support payment records of the Texas Child Support Disbursement Unit.

This payment record is admissible in a court proceeding as evidence of payments made through the Texas Child Support Disbursement Unit pursuant to Texas Family Code Section 157.002(b)(3), Section 157.162(c), and Section 234.001(d).

Page 3 of 7

Office of the Attorney General Texas Child Support Disbursement Unit Payment Record Payment Date Payment Amount Cause ID (MM/DD/YYYY) 02/01/2012 383.96 703024 01/17/2012 400.00 703024 12/19/2011 400.00 703024 12/16/2011 400.00 703024 12/01/2011 550.00 703024 11/16/2011 250.00 703024 11/01/2011 250.00 703024 10/17/2011 250.00 703024 10/03/2011 69.24 703024 09/30/2011 250.00 703024 09/19/2011 69.24 703024 09/16/2011 250.00 703024 09/01/2011 250.00 703024 08/16/2011 250.00 703024 07/29/2011 250.00 703024 07/15/2011 250.00 703024 07/01/2011 250.00 703024 06/16/2011 250.00 703024 06/01/2011 250.00 703024 05/16/2011 250.00 703024 05/02/2011 250.00 703024 04/18/2011 250.00 703024 04/01/2011 250.00 703024 03/14/2011 250.00 703024 03/02/2011 250.00 703024 02/16/2011 250.00 703024 02/01/2011 250.00 703024 01/18/2011 250.00 703024 12/20/2010 250.00 703024 12/16/2010 250.00 703024 12/01/2010 250.00 703024 11/16/2010 250.00 703024

Thisis a true and correct copy of the computerized official child support payment records of the Texas Child Support Disbursement Unit.

This payment record is admissible in a court proceeding as evidence of payments made through the Texas Child Support Disbursement Unit pursuant to Texas Family Code Section 157.002(b)(3), Section 15'/.162(o), and Section 234.001(d).

Page 4 of 7

Office of the Attorney General Texas Child Support Disbursement Unit Payment Record Payment Date Payment Amount Cause ID (MM/DD/YYYY) 11/01/2010 250.00 703024 10/18/2010 250.00 703024 10/01/2010 250.00 703024 09/16/2010 250.00 703024 09/01/2010 299.32 703024 07/12/2010 69.24 703024 07/06/2010 69.24 703024 07/01/2010 250.00 703024 06/28/2010 69.24 703024 06/21/2010 69.24 703024 06/16/2010 250.00 703024 06/14/2010 69.24 703024 06/07/2010 69.24 703024 06/01/2010 69.24 703024 06/01/2010 250.00 703024 05/24/2010 69.24 703024 05/17/2010 69.24 703024 05/14/2010 250.00 703024 05/10/2010 69.24 703024 05/03/2010 69.24 703024 05/03/2010 250.00 703024 04/26/2010 69.24 703024 04/19/2010 69.24 703024 04/16/2010 250.00 703024 04/12/2010 69.24 703024 04/05/2010 69.24 703024 04/01/2010 250.00 703024 03/29/2010 69.24 703024 03/22/2010 69.24 703024 03/15/2010 69.24 703024 03/15/2010 250.00 703024 03/08/2010 69.24 703024

Thisis a true and correct copy of the computerized official child support payment records of the Texas Child Support Disbursement Unit.

This payment record is admissible in a court proceeding as evidence of payments made through the Texas Child Support Disbursement Unit pursuant to Texas Family Code Section 157.002(b)(3), Section 157.162(c), and Section 234.001(d).

Page 5 of 7

Office of the Attorney General Texas Child Support Disbursement Unit Payment Record Payment Date Payment Amount Cause lD (MM/DD/YYYY) 03/01/2010 69.24 703024 03/01/2010 250.00 703024 02/22/2010 69.24 703024 02/16/2010 69.24 703024 02/16/2010 250.00 703024 02/08/2010 69.24 703024 02/01/2010 69.24 703024 01/29/2010 250.00 703024 01/25/2010 69.24 703024 01/19/2010 69.24 703024 01/15/2010 250.00 703024 01/11/2010 69.24 703024 01/04/2010 69.24 703024 12/28/2009 69.24 703024 12/21/2009 69.24 703024 12/21/2009 250.00 703024 12/16/2009 250.00 703024 12/14/2009 69.24 703024 12/07/2009 69.24 703024 11/30/2009 69.24 703024 11/30/2009 250.00 703024 11/23/2009 69.24 703024 11/16/2009 69.24 703024 11/16/2009 250.00 703024 11/09/2009 69.24 703024 11/02/2009 250.00 703024 11/02/2009 69.24 703024 10/26/2009 205.28 703024 10/19/2009 205.28 703024 10/16/2009 311.84 703024 10/13/2009 205.28 703024 10/05/2009 205.28 703024

Thisis a true and correct copy of the computerized official child support payment records of the Texas Child Support Disbursement Unit.

This payment record is admissible in a court proceeding as evidence of payments made through the Texas Child Support Disbursement Unit pursuant to Texas Family Code Section 157.002(b)(3), Section 157.162(c), and Section 234.001(d).

Page 6 of 7

Office of the Attorney General Texas Child Support Disbursement Unit Payment Record Payment Date Payment Amount Cause ID (MM/DD/YYYY) 10/01/2009 316.24 703024 09/28/2009 205.28 703024 09/22/2009 362 .79 703024 09/21/2009 205.28 703024 08/31/2009 300.06 703024 08/17/2009 300.06 703024 08/03/2009 549.92 703024 07/16/2009 524.20 703024

Thisis a true and correct copy of the computerized official child support payment records of the Texas Child Support Disbursement Unit.

This payment record admissible in a court proceeding as evidence of payments made through the Texas Child Support is

Disbursement Unit pursuant to Texas Family Code Section 157.002(b)(3), Section 157.162(c), and Section 234.001(d).

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