Hhse - JSJ Ozark Bank Garnishment

ELECTRONICALLY FILED
Washington County Circuit Court

Kyle Sylvester, Circuit Clerk
2018-Nov-01 14:08:21
72CV-16-2428
C04D02 : 38 Pages
IN THE CIRCUIT COURT OF WASHINGTON COUNTY, ARKANSAS

CIVIL DIVISION
JSJ INVESTMENTS, INC. PLAINTIFF
VS. Case No. 72CV-16-2428(II)
HANNOVER HOUSE, INC. DEFENDANT
BANK OZK GARNISHEE
MOTION FOR ORDER OF

GARNISHMENT TO BANK OZK
COMES NOW JSJ Investments (“JSJ”), and for its Motion for Order of Garnishment,
states as follows:
1. JSJ obtained a Judgment in this Court against the Defendant, Hannover House,
Inc., which was filed for record on October 6, 2016. The original amount of the Judgment was
$369,368.61, plus post-judgment interest at the rate of 12% per annum from October 6, 2016.
The Judgment remains unsatisfied.
2. On August 21, 2018, JSJ obtained a Writ of Garnishment (the “Writ”) upon the
Judgment. See Writ of Garnishment, a true and correct copy of which is attached hereto as
Exhibit A.
3. As of the filing of the Writ, the Judgment was calculated as follows:
JUDGMENT DEBTOR: Hannover House, Inc.

ORIGINAL JUDGMENT: $369,368.61
DATE OF JUDGMENT: October 6, 2016
INTEREST FROM FEBRUARY 13, 2018,
UNTIL SATISFACTION: 12% per annum
AMOUNT OF INTEREST FROM JUDGMENT
ON FEBRUARY 13, 2018, TO WRIT: $81,726.60
OTHER: (this Writ $20.00) $20.00
TOTAL $451,115.21
MOTION FOR ORDER OF Page 1 of 3
44250.0001/6639129.1
4. In addition, interest continues to accrue at the rate of $148.31 per diem for each
day after August 21, 2018 (date of writ).
5. Garnishee responded to the Writ on September 21, 2018. See Answer to
Allegations and Interrogatories, attached hereto as Exhibit B.
6. Garnishee confirmed that Defendant maintains one checking account with
Garnishee which had a negative balance on the date of the Writ. See Ex. B.
7. But, in a post-judgment deposition of Defendant’s COO, Fred Shefte, he
confirmed that Defendant only maintains one corporate bank account, which is the account at
issue. See Deposition of Fred Shefte (excerpted), attached hereto as Exhibit C.
8. Therefore, as the sole operating account of Defendant, JSJ is entitled to
garnishment of any funds deposited in such account.
9. Defendant was served with the Writ. See Correspondence, attached hereto as
Exhibit D.
10. Defendant has not filed any objections or responses to the issuance of the Writ
with the Court.
11. JSJ is entitled to an Order on the Writ directing release of the funds held by
Garnishee, and all future amounts subject to the Writ, be made to JSJ.
WHEREFORE, for the above stated reasons, JSJ respectfully requests that this Court
grant this Motion, order that any funds deposited in this account be remitted to JSJ, and for all
other relief deemed appropriate.

44250.0001/6639129.1
Respectfully submitted,
Marshall S. Ney (91108)
Kael K. Bowling (2016220)
FRIDAY, ELDREDGE & CLARK, LLP
3350 S. Pinnacle Hills Parkway, Suite 301
Rogers, Arkansas 72758
479-695-6049 Office
501-244-5389 Facsimile
By: /s/ Kael K. Bowling

Kael K. Bowling
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I, Kael K. Bowling, hereby certify that on this 1st day of November, 2018, a true and
correct copy of the foregoing was served on the following via the Court’s eFlex system and/or
regular mail to:
Michael J. Ptak Hannover House, Inc.

P.O. Box 8811 300 North College Ave., Suite 311
Little Rock, AR 72231-8811 Fayetteville, AR 72703
/s/ Kael K. Bowling

Kael K. Bowling

44250.0001/6639129.1
IN THE CIRCUIT COURT OF WASHINGTON COUNTY,ARKANSAS
CIVIL DIVISION
JSJ INVESTMENTS,INC. PLAINTIFF
V. 72CV-16-2428(H)
HANNOVER HOUSE,INC. DEFENDANT
BANK OZK,f/k/a BANK OF THE OZARKS GARNISHEE
WRIT OF GARNISHMENT
TO THE ABOVE NAMED GARNISHEE:
1. A judgment has been obtained in this Court in favor of the Plaintiff against Defendants,
Hannover House, Inc., in the amount of $369,368.61, together with post-judgment interest at
the rate of 12% per annum from October 6, 2016, until present, and the judgment remains
unsatisfied.
2. The Gamishee is directed to prepare a written answer, under oath, and to file this answer in
the Washington County Circuit Clerk's office within thirty (30) days from the date on which
it was served with this Writ. Ifthe Gamishee is a partnership or corporation, the answer must
be prepared by a licensed attorney. The written answer should contain a statement of what
goods, chattels, moneys, credits, or effects the Gamishee may possess belonging to Hannover
House, Inc. to satisfy this Judgment. Unless the Gamishee files such written answer within
thirty (30) days,judgment may be entered against it for the full amount owed by Hannover
House, Inc., together with the court costs of this action.
j. In addition, the Gamishee is required to answer any further Interrogatories that may be
propounded.
4. There are federal restrictions on the amount that the Gamishee may withhold from an
employee's pay. Please consult Wage-Hour Publication No. 1279, obtainable from the United
States Department ofLabor, Wage and Hour Division.
5. The Gamishee should not pay any money to the Clerk, but should hold the money until a
Court order directs it to be released.
6. Please read the various Notices attached to this Writ of Gamishment. If you are an
employer-gamishee, this garnishment is continuous until the total amount is paid in full or
the employee is terminated. Please remit the proper amount each pay period.
WRIT OF GARNISHMENT tBANK OZK.f/k/a BANK OF THE OZARKS)

44250.0001/6428880.1
7. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT
TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE.
1. EXPLANATION

OTHER: (this Writ $20.00) $20.00
TOTAL $451,115.21
IN TESTIMONY HEREOF, I have hereunto set my hand and affixed the seal of said Court this
_____ day of August, 2018.
WASHINGTON COUNTY CIRCUIT CLERK
BY: _____________________________
DEPUTY CLERK
WRIT OF GARNISHMENT(BANK OZK, f/k/a BANK OF THE OZARKS) Page 2 of 3

44250.0001/6428880.1
NOTICE TO DEFENDANT OF YOUR RIGHT TO KEEP WAGES,
MONEY, AND OTHER PROPERTY FROM BEING GARNISHED
The Writ of Garnishment or Writ of Execution delivered to you with this Notice means that wages,
money, or other property belonging to you has been garnished in order to pay a court judgment against you.
HOWEVER, YOU MAY BE ABLE TO KEEP YOUR MONEY OR PROPERTY FROM BEING TAKEN,
SO READ THIS NOTICE CAREFULLY.
State and federal laws say that certain money and property may not be taken to pay certain types of
court judgments. Such money or property is said to be “exempt” from garnishment.
For example, under the Arkansas Constitution and state law, you will be able to claim as exempt all
or part of your wages or other personal property. As another example, under federal law Social Security, SSI,
Veteran’s benefits, AFDC (welfare), unemployment compensation, and workers’ compensation are also
exempt from garnishment.
You have a right to ask for a court hearing to claim these or other exemptions. If you need legal
assistance to help you try to save your wages or property from being garnished, you should see a lawyer. If
you can’t afford a lawyer, contact your local bar association or ask the clerk’s office about a legal services
program in your area.
NOTICE TO EMPLOYER GARNISHEE
The amount of wages available for withholding for this judgment and costs is subject to certain prior
claims. Under Arkansas law, income withholding for child support has a priority over all other legal
processes. Under federal law, the total amount to be withheld cannot exceed the maximum amount allowed
under § 303(b) of the Title III Consumer Credit Protection Act. [15 U.S.C. § 1673] The lien provided by this
Writ of Garnishment shall continue as to subsequent earnings until the total amount due upon the judgment
and costs is paid or satisfied.
Failure to answer this Writ within thirty (30) days or failure or refusal to answer the
Interrogatories attached hereto shall result in the court entering a judgment against you and you becoming
personally liable for the amount of the non-exempt wages owed the debtor-employee on the date you were
served this Writ as provided by Arkansas Code Annotated § 16-110-407.
NOTICE TO NON-EMPLOYER GARNISHEE
Failure to answer this writ within thirty (30) days or failure or refusal to answer the
Interrogatories attached hereto shall result in the court entering a judgment against you and you
becoming personally liable for the full amount specified in this Writ together with costs of this action as
provided by Arkansas Code Annotated § 16-110-407.
WRIT OF GARNISHMENT(BANK OZK, f/k/a BANK OF THE OZARKS) Page 3 of 3

44250.0001/6428880.1
Arkansas Judiciary
Case Title: JSJ INVESTMENTS INC V HANNOVER HOUSE INC
Case Number: 72CV-16-2428
Type: WRIT OF GARNISHMENT ISSUED WITH FEE
So Ordered
Pamela Penn, Washington County

Deputy Clerk
Electronically signed by PSPENN on 2018-08-21 07:50:24 page 4 of 4

2018-Aug-20 10:27:40
72CV-16-2428
C04D02 : 3 Pages

CIVIL DIVISION
V. 72CV-16-2428 (II)
BANK OZK, f/k/a BANK OF THE OZARKS GARNISHEE
PLAINTIFF’S ALLEGATIONS AND INTERROGATORIES TO GARNISHEE
Plaintiff, JSJ Investments, Inc. (“Plaintiff”), for its Allegations and Interrogatories to
BankOZK, f/k/a Bank Of The Ozarks (“Garnishee”) as they relate to separate Defendant
Hannover House, Inc. (“Defendant”) alleges that:
1. The Garnishee was on and after the date of service of the Writ of Garnishment indebted
to the Defendant.
2. Upon information and belief, Defendant is employed by and receives wages or other
compensation from Garnishee, and Plaintiff is entitled to garnish Defendant’s wages or other
compensation from Garnishee pursuant to Ark. Code. Ann. Sect. 16-110-401 et. seq.
And Plaintiff propounds to the Garnishee the following Interrogatories:
INTERROGATORY NO. 1: Is Defendant employed by Garnishee or any related
entity? If so, what amount or rate of wages or other compensation does Defendant receive from
Garnishee or any related entity?
INTERROGATORY NO. 2: Is Defendant employed by an entity related to Garnishee?
If so, please provide the name, address, and contact information for the related entity.
PLAINTIFF’S ALLEGATIONS AND INTERROGATORIES Page 1 of 3

TOBANK OZK, f/k/a BANK OF THE OZARKS, GARNISHEE
44250.0001/6428905.1
INTERROGATORY NO. 3: Was Garnishee indebted in any way to Defendant on or
after the date of service of the Writ of Garnishment? If so, list and explain how you are indebted
to Defendant and in what amount.
INTERROGATORY NO. 4: Did Garnishee have in its possession on or after the
service of this Writ of Garnishment any goods, chattels, monies, credits, or effects belonging to
Defendant? If so, please list and identify the nature and value of all such goods, chattels,
monies, credits, or effects.
INTERROGATORY NO. 5: If Garnishee’s response to Interrogatory No. 1 is not in the
affirmative, please list:
(a) The date Defendant’s employment ended with Garnishee;
(b) Any contact information Garnishee has concerning Defendant’s employment after
his employment ended with Garnishee.
JSJ INVESTMENTS, INC., Plaintiff
By: /s/ Kael K. Bowling_________________________

FRIDAY, ELDREDGE & CLARK, LLP
3425 N. Futrall Drive, Suite 103
Fayetteville, AR 72703-4811
Telephone: (479) 695-2011
Facsimile: (501) 244-5333
Attorneys for JSJ Investments, Inc.

TO BANK OZK, f/k/a BANK OF THE OZARKS, GARNISHEE
44250.0001/6428905.1
I, Kael K. Bowling, hereby certify that on this 20th day of August, 2018, a true and correct
copy of the foregoing was mailed, postage prepaid, by U.S. Postal Service first-class certified mail,
to:
Hannover House, Inc.
300 North College Avenue
Suite 311
Fayetteville, AR 72703
I further certify that I have on this date mailed to Hannover House, Inc. at 300 North
College Avenue, Suite 311, Fayetteville, AR 72703, the foregoing and that if it is returned
“undeliverable” by the post office, or if the residence of the judgment debtor is not discoverable
after diligent search, then the foregoing document shall be sent by first-class mail to the judgment
debtor at his or her place of employment, if known.
/s/ Kael K. Bowling

Kael K. Bowling

TO BANK OZK, f/k/a BANK OF THE OZARKS, GARNISHEE
44250.0001/6428905.1
2018-Sep-21 15:11:30
72CV-16-2428
C04D02:2 Pages

CIVIL DIVISION
JSJ INVESTMENTS,INC. )
PLAINTIFF )
)
VS. Case No.72CV-16-2428(11) )
)
HANNOVER HOUSE,INC. )
DEFENDANT)
)
BANK OZK )
GARNISHEE )
ANSWER TO WRIT OF GARNISHMENT
Bank OZK, formerly known as Bank of the Ozarks (hereinafter referred to as "Bank
OZK"), the Garnishee named herein, for its Answer to the Writ of Garnishment served upon it,
states as follows:
1. On and after the date of service of the Writ of Garnishment, Defendant Hannover
House, Inc. maintained one (1) checking account with Bank OZK. However, on and after the
date of service ofthe Writ of Garnishment, such checking account had a negative balance.
2. Bank OZK did not have in its hands or possession, on or after the date of service
of the Writ of Garnishment upon it, any goods, chattels, credits, personal property, or other
effects belonging to Defendant Hannover House, Inc.
WHEREFORE,Bank OZK,the Garnishee named herein, having fully answered, prays
that the Court examine its Answer and enter an order directing that Bank OZK be discharged and
released from any further liability to Plaintiff JSJ Investments, Inc. or Defendant Hannover
House, Inc. in connection with the Writ of Garnishment and that it be dismissed from this action.
§ EXHIBIT
2018-Sep-21 15:11:30
72CV-16-2428
C04D02 : 3 Pages
Fred Shefte Augusts, 2018
*** * ** ** **
VS. NO. 72CV-16-2428
*** * ** ** **
DEPOSITION OF
FRED SHEFTE
* * * * *** * **
APPEARANCES:
FOR THE PLAINTIFF:
MR. KAEL K. BOWLING

Friday, Eldredge & Clark, LLP
Fayetteville, Arkansas 72703
DATE: Wednesday, August 8, 2018
TIME: 9:13 a.m. to 11:27 a.m.
PLACE: Friday, Eldredge & Clark
3350 S. Pinnacle Hills Parkway, Suite 301
Rogers, Arkansas
Dunn Court Reporting Services, Inc. EXHIBIT

479-790-0476
Fred Shefte August 8, 2018
Page 2
C A P T I O N
FRED SHEFTE, the witness, appeared before Dianna Dunn, a
Notary Public within and for the County of Washington, State of
Arkansas, at the time and place heretofore stated; at which time,
a Deposition was taken in a certain cause now pending, in
accordance with the Arkansas Rules of Civil Procedure.
_ _ _
S T I P U L A T I O N S
It is hereby stipulated and agreed by and between the
parties, hereto by counsel, that all formalities as to the taking
of said deposition are hereby waived; including presentation,
reading, and signing by the witness; that all objections as to
relevancy, materiality and competency are expressly reserved,
except as to the form of the question, and may be raised if and
when said deposition, or any part thereof, is offered at the trial
of said cause.
Dunn Court Reporting Services, Inc.

479-790-0476
Fred Shefte August 8, 2018
Page 44
1 A A question remains about Big Hat Enterprises. I don’t
2 believe that the stock has been issued.
3 Q Other than those four and we’ll include Big Hat in that
4 exclusion?
5 A I don’t believe so.
6 Q What about does Hannover own any bonds?
7 A No.
8 Q Does Hannover own any other securities that I haven’t asked
9 about?
10 A No.
11 Q Other than the single Ford F80 whose Certificate of Title
12 you’ve provided to me, does Hannover own any vehicles?
13 A No.
14 Q Does Hannover own any boats or planes?
15 A No.
16 Q Any other motor vehicles?
17 A No.
18 Q Do you know how many corporate bank accounts Hannover has?
19 A Hannover House has one.
20 Q Is Hannover House a signatory on any other bank accounts?
21 A No.
22 Q At what bank is that account located?
23 A Bank of the Ozarks and I provided you with the last two
24 statements.
25 Q What about Medallion Releasing? Does it have any bank
Dunn Court Reporting Services, Inc.

479-790-0476
Kael K. Bowling| Attorney 3425 North Futrall Drive
PDin AVI eldredge
rr%II^A\T I & Clark LLP
Direct:(479) 695-2118
Fax:(501) 244-5333
Suite 103
Fayetteville, Arkansas 72703
E-mail: kbowllng@fridayflrm.com www.FridayFirm.com
August 21, 2018
Certified Mail-Return Receipt Requested

Restricted Delivery
Tracking #70161970 0000 81872869
BankOzk
17901 Chenal Parkway
Little Rock, AR 72223
Re: JSJInvestments v. Hannover House

Washington County Cir. Ct., AR; Case No.72CV-16-2428 ai)
Dear Sir or Madam:
This firm represents JSJ Investments, Inc. in the above-captioned matter. Enclosed
please find an issued Writ of Garnishment and Plaintiffs Allegations and Interrogatories to
Gamishee for your response as Gamishee.
By copy of this letter and enclosure, I am providing a copy of the Writ and discovery
requests to all parties ofrecord.
Please do not hesitate to contact me if you wish to discuss this matter.
Sincerely
Kael K. Bowling
KKB:fsw
Enclosures
cc: Hannover House,Inc.

300 North College Ave., Suite 311
EXHIBIT
44250.0001/6442882.1
SENDER: COMPLETE THIS SECTION COMPLETE THIS SECTION ON DELIVERY
7
■ Complete items 1,2, and 3. A. Signature
■ Print your name and address on the reverse y □ Agent

so that we can return the card to you. □ Addressee (
B. Received by printed Name) 0. Date of Delivery
■ Attach this card to the back of the maiipiece,
or on the front if space permits.
1. Article Addressed to: D. Is delivery address different from item 1? □ Yes J
if YES, enter delivery address below: □ No '
Bank Ozk
17901 Chenai Parkway {
Little Rock, AR 72223 .1
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CIVIL DIVISION
V. 72CV-16-2428(H)
WRIT OF GARNISHMENT
unsatisfied.
the Washington County Circuit Clerk's office within thirty(30) days from the date on which
it was served with this Writ. Ifthe Gamishee is a partnership or corporation, the answer must
House, Inc., together with the court costs of this action.
3. In addition, the Gamishee is required to answer any further Interrogatories that may be
propounded.
States Department of Labor, Wage and Hour Division.
employer-gamishee, this gamishment is continuous until the total amount is paid in full or
WRIT OF GARNISHMENT tBANK OZK.f/k/a BANK OF THE OZARKSt Page 1 of3

44250.0001/6428880.1
THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT
THAT PURPOSE.
1. EXPLANATION

DATE OF JUDGMENT: October 6,2016
OTHER: Ithis Writ $20.001 $20.00
TOTAL $451,115.21
IN TESTIMONY HEREOF,I have hereunto set my hand and affixed the seal of said Court this
day of August, 2018.
BY:
DEPUTY CLERK
WRIT OF GARNISHMENTtBANK OZK.f/k/a BANK OF THE OZARKSt Page 2 of3

44250.0001/6428880.1
NOTICE TO DEFENDANT OF YOUR RIGHT TO KEEP WAGES.
MONEY.AND OTHER PROPERTY FROM BEING GARNISHED
HOWEVER,YOU MAY BE ABLE TO KEEP YOUR MONEY OR PROPERTY FROM BEING TAKEN,
courtjudgments. Such money or property is said to be "exempt" from garnishment.
Veteran's benefits, AFDC (welfare), unemployment compensation, and workers' compensation are also
you can't afford a lawyer, contact your local bar association or ask the clerk's office about a legal services
under § 303(b)ofthe Title III Consumer Credit Protection Act.[15 U.S.C. § 1673] The lien provided by this
personally liable for the amount ofthe non-exempt wages owed the debtor-employee on the date you were
served this Writ as provided by Arkansas Code Annotated § 16-110-407.
becoming personally liable for the full amount specified in this Writ together with costs of this action as
WRIT OF GARNISHMENTIBANK OZK.f/k/a BANK OF THE OZARKSI Page 3 of3

44250.0001/6428880.1
Arkansas Judiciary
So Ordered
m**. .'i^/

Deputy Clerk

Kyie Syivester, Circuit Cierk
2018-Aug-20 10:27:40
72CV-16-2428
C04D02:3 Pages

CIVIL DIVISION
V. 72CV-16-2428(H)
PLAINTIFF'S ALLEGATIONS AND INTERROGATORIES TO GARNISHEE
Plaintiff, JSJ Investments, Inc. ("Plaintiff), for its Allegations and Interrogatories to
BankOZK, f/k/a Bank Of The Ozarks ("Garnishee") as they relate to separate Defendant
Hannover House,Inc.("Defendant") alleges that:
to the Defendant.
2. Upon information and belief. Defendant is employed by and receives wages or other
compensation from Garnishee, and Plaintiff is entitled to garnish Defendant's wages or other
compensation from Garnishee pursuant to Ark. Code. Ann. Sect. 16-110-401 et. seq.
And Plaintiff propounds to the Garnishee the following Interrogatories:
INTERROGATORY NO.2: Is Defendant employed by an entity related to Garnishee?
PLAINTIFF'S ALLEGATIONS AND INTERROGATORIES Page 1 of3

TOBANK OZK.f/k/a BANK OF THE OZARKS.GARNISHEE
44250.0001/6428905.1
INTERROGATORY NO. 3: Was Gamishee indebted in any way to Defendant on or
after the date of service ofthe Writ of Garnishment? If so, list and explain how you are indebted
INTERROGATORY NO. 4: Did Gamishee have in its possession on or after the
service of this Writ of Gamishment any goods, chattels, monies, credits, or effects belonging to
INTERROGATORY NO.5: If Gamishee's response to Interrogatory No. 1 is not in the
(a) The date Defendant's emplojmient ended with Gamishee;
(b) Any contact information Gamishee has conceming Defendant's employment after
his employment ended with Gamishee.
JSJ INVESTMENTS,INC., Plaintiff
By: /s/Kael K. Bowline

Kael K. Bowling(2016220)
FRIDAY,ELDREDGE & CLARK,LLP
3425 N.Futrall Drive, Suite 103
Telephone:(479)695-2011
Facsimile:(501)244-5333
Attorneysfor JSJInvestments, Inc.

TO BANK OZK.f/k/a BANK OF THE OZARKS. GARNISHEE
44250.0001/6428905.1
copy ofthe foregoing was mailed, postage prepaid, by U.S. Postal Service first-class certified mail,
to:

Suite 311
I further certify that I have on this date mailed to Hannover House, Inc. at 300 North
College Avenue, Suite 311, Fayetteville, AR 72703, the foregoing and that if it is returned
"undeliverable" by the post office, or if the residence of the judgment debtor is not discoverable
debtor at his or her place ofemployment, if known.
/s/Kael K. Bowline
Kael K. Bowling

44250.0001/6428905.1
Kael K. Bowling | Attorney 3425 North Futrall Drive
FRIDAY I & Clark LLP Direct: (479) 695-2118

Fax: (501) 244-5333
E-mail: kbowiing@fridayfirm.com
Suite 103
Fayetteviiie, Arkansas 72703
www.FridayFirm.com
August 21,2018
Certified Mail-Return Receipt Requested

Restricted Delivery
Tracking #70161970 0000 81872784
Bank Ozk
Attn: Greg McKinney
P.O. Box 8811
Little Rock, AR 72231-8811
Re: JSJInvestments v. Hannover House

Washington County Cir. Ct., AR; Case No. 72CV-16-2428 (II)
Dear Sir or Madam:
This firm represents JSJ Investments, Inc. in the above-captioned matter. Enclosed
please find an issued Writ of Garnishment and Plaintiffs Allegations and Interrogatories to
Gamishee for your response as Gamishee.
By copy of this letter and enclosure, I am providing a copy of the Writ and discovery
requests to all parties of record.
Please do not hesitate to contact me if you wish to discuss this matter.
Sincerely
Kael K. Bowling
KKB:fsw
Enclosures
cc: Hannover House,Inc.

300 North College Ave., Suite 311
Fayetteviiie, AR 72703
44250.0001/6437366.1
U.S. Postal Service™
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Complete Items 1,2, and 3. A. Signature

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Attach this card to the back of the mallpiece, B. Received by (Pr/nieof Warned C. Date of Delivery
or on the front If space permits.
H Ai^Jnla AHrlrA.Q<%c^ tQ!
D. Is deiivery address different from item 1? □ Yes ,
If YES, enter delivery address below: □ No
Bank Ozk
Attn: Greg McKinney
P.O. Box 8811
3. Service Type □ Priority Mall Express®
iliii □ Adult Signature

□ AJ
ertified Mall®
□ Registered Mall™ ,
□ Registered Mall Restricted'
Peifvety
9590 9403 0432 5163 3077 22 □ Certified Mall Restricted Delivery jaroturn Recelptfcr
□ Collect on Delivery Merctrandlse
! 2. M.\c\e Number (Transfer frpm service label) P Collect on Delivery Restricted Delivery □ Signature Confirmation™ i
□ Insured Mall □ Signature Confirmation
□ Insured Mall Restricted Delivery Restricted Delivery
i 7Dlb n7D DDDD 6167 H76M (over $500)
• PS Form 3811, April 2015 PSN 7530-02-000-9053 Domestic Return Receipt
CIVIL DIVISION
V. 72CV-16-2428(H)
WRIT OF GARNISHMENT
unsatisfied.
the Washington County Circuit Clerk's office within thirty (30) days from the date on which
it was served with this Writ. If the Gamishee is a partnership or corporation, the answer must
House, Inc., together with the court costs ofthis action.
3. In addition, the Gamishee is required to answer any further Interrogatories that may be
propounded.
States Department ofLabor, Wage and Hour Division.
employer-gamishee, this gamishment is continuous until the total amount is paid in full or
WRIT OF GARNISHMENT(BANK OZK.f/k/a BANK OF THE OZARKSl Page 1 of3

44250.0001/6428880.1
7. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT
THAT PURPOSE.
1. EXPLANATION

OTHER: Tthis Writ $20.001 $20.00
TOTAL $451,115.21
IN TESTIMONY HEREOF,I have hereunto set my hand and affixed the seal of said Court this
day of August,2018.
BY:
DEPUTY CLERK
WRIT OF GARNISHMENTtBANK OZK.f/k/a BANK OF THE OZARKS) Page 2 of3

44250.0001/6428880.1
NOTICE TO DEFENDANT OF YOUR RIGHT TO KEEP WAGES.
MONEY.AND OTHER PROPERTY FROM BEING GARNISHED
HOWEVER,YOU MAY BE ABLE TO KEEP YOUR MONEY OR PROPERTY FROM BEING TAKEN,
courtjudgments. Such money or property is said to be "exempt" from garnishment.
Veteran's benefits, AFDC (welfare), unemployment compensation, and workers' compensation are also
you can't afford a lawyer, contact your local bar association or ask the clerk's office about a legal services
imder § 303(b)ofthe Title III Consumer Credit Protection Act.[15 U.S.C. § 1673] The lien provided by this
personally liable for the amount ofthe non-exempt wages owed the debtor-employee on the date you were
served this Writ as provided by Arkansas Code Annotated § I6-110-407.
becoming personally liable for the full amoimt specified in this Writ together with costs of this action as
WRIT OF GARNISHMENTIBANK OZK.f/k/a BANK OF THE OZARKSI Page 3 of3

44250.0001/6428880.1
Arkansas Judiciary
So Ordered

Deputy Clerk

Kyie Syivester, Circuit Cierk
2018-Aug-20 10:27:40
72CV-16-2428
C04D02: 3 Pages

CIVIL DIVISION
V. 72CV-16-2428(H)
PLAINTIFF'S ALLEGATIONS AND INTERROGATORIES TO GARNISHEE
Plaintiff, JSJ Investments, Inc. ("Plaintiff), for its Allegations and Interrogatories to
BankOZK, f/k/a Bank Of The Ozarks ("Garnishee") as they relate to separate Defendant
Hannover House, Inc.("Defendant") alleges that:
to the Defendant.
2. Upon information and belief. Defendant is employed by and receives wages or other
compensation from Garnishee, and Plaintiff is entitled to garnish Defendant's wages or other
compensation from Garnishee pursuant to Ark. Code. Arm. Sect. 16-110-401 et. seq.
And Plaintiff propoimds to the Garnishee the following Interrogatories:
INTERROGATORY NO. 2: Is Defendant employed by an entity related to Garnishee?
PLAINTIFF'S ALLEGATIONS AND INTERROGATORIES Page 1 of 3

TOBANK OZK.f/k/a BANK OF THE OZARKS.GARNISHEE
44250.0001/6428905.1
INTERROGATORY NO. 3: Was Gamishee indebted in any way to Defendant on or
after the date of service ofthe Writ of Garnishment? If so, list and explain how you are indebted
INTERROGATORY NO. 4: Did Gamishee have in its possession on or after the
service of this Writ of Gamishment any goods, chattels, monies, credits, or effects belonging to
INTERROGATORY NO.5: If Gamishee's response to Interrogatory No. I is not in the
(a) The date Defendant's employment ended with Gamishee;
(b) Any contact information Gamishee has concerning Defendant's employment after
his employment ended with Gamishee.
JSJ INVESTMENTS,INC.,Plaintiff
By: /s/KaelK. Bowlins

FRIDAY,ELDREDGE & CLARK,LLP
Telephone:(479)695-2011
Facsimile:(501)244-5333
Attorneysfor JSJInvestments, Inc.
PLAINTIFF'S ALLEGATIONS AND INTERROGATORIES Page 2 of 3

TO BANK OZK.f/k/a BANK OF THE OZARKS.GARNISHEE
44250.0001/6428905.1
copy ofthe foregoing was mailed, postage prepaid, by U.S. Postal Service first-class certified mail,
to:

Suite 311
1 further certify that I have on this date mailed to Hannover House, Inc. at 300 North
College Avenue, Suite 311, Fayetteville, AR 72703, the foregoing and that if it is retumed
"undeliverable" by the post office, or if the residence of the judgment debtor is not discoverable
debtor at his or her place ofemployment,if known.
A/Kael K. Bowline
Kael K. Bowling
PLAINTIFF'S AT J.EGATTONS AND INTERROGATORIES Page 3 of3

44250.0001/6428905.1

Hhse - JSJ Ozark Bank Garnishment

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ELECTRONICALLY FILED

Washington County Circuit Court

IN THE CIRCUIT COURT OF WASHINGTON COUNTY, ARKANSAS

JSJ INVESTMENTS, INC. PLAINTIFF

VS. Case No. 72CV-16-2428(II)

HANNOVER HOUSE, INC. DEFENDANT

BANK OZK GARNISHEE

MOTION FOR ORDER OF

The Judgment remains unsatisfied.

3. As of the filing of the Writ, the Judgment was calculated as follows:

JUDGMENT DEBTOR: Hannover House, Inc.

day after August 21, 2018 (date of writ).

5. Garnishee responded to the Writ on September 21, 2018. See Answer to

Allegations and Interrogatories, attached hereto as Exhibit B.

6. Garnishee confirmed that Defendant maintains one checking account with

7. But, in a post-judgment deposition of Defendant’s COO, Fred Shefte, he

issue. See Deposition of Fred Shefte (excerpted), attached hereto as Exhibit C.

8. Therefore, as the sole operating account of Defendant, JSJ is entitled to

garnishment of any funds deposited in such account.

with the Court.

other relief deemed appropriate.

MOTION FOR ORDER OF Page 2 of 3

By: /s/ Kael K. Bowling

Attorney for Plaintiff

Michael J. Ptak Hannover House, Inc.

/s/ Kael K. Bowling

MOTION FOR ORDER OF Page 3 of 3

JSJ INVESTMENTS,INC. PLAINTIFF

HANNOVER HOUSE,INC. DEFENDANT

BANK OZK,f/k/a BANK OF THE OZARKS GARNISHEE

TO THE ABOVE NAMED GARNISHEE:

WRIT OF GARNISHMENT tBANK OZK.f/k/a BANK OF THE OZARKS)

JUDGMENT DEBTOR: Hannover House, Inc.

WASHINGTON COUNTY CIRCUIT CLERK

WRIT OF GARNISHMENT(BANK OZK, f/k/a BANK OF THE OZARKS) Page 2 of 3

NOTICE TO EMPLOYER GARNISHEE

NOTICE TO NON-EMPLOYER GARNISHEE

WRIT OF GARNISHMENT(BANK OZK, f/k/a BANK OF THE OZARKS) Page 3 of 3

Case Title: JSJ INVESTMENTS INC V HANNOVER HOUSE INC

Case Number: 72CV-16-2428

Type: WRIT OF GARNISHMENT ISSUED WITH FEE

Pamela Penn, Washington County

Electronically signed by PSPENN on 2018-08-21 07:50:24 page 4 of 4

IN THE CIRCUIT COURT OF WASHINGTON COUNTY, ARKANSAS

JSJ INVESTMENTS, INC. PLAINTIFF

HANNOVER HOUSE, INC. DEFENDANT

BANK OZK, f/k/a BANK OF THE OZARKS GARNISHEE

PLAINTIFF’S ALLEGATIONS AND INTERROGATORIES TO GARNISHEE

Hannover House, Inc. (“Defendant”) alleges that:

And Plaintiff propounds to the Garnishee the following Interrogatories:

INTERROGATORY NO. 1: Is Defendant employed by Garnishee or any related

Garnishee or any related entity?

INTERROGATORY NO. 2: Is Defendant employed by an entity related to Garnishee?

PLAINTIFF’S ALLEGATIONS AND INTERROGATORIES Page 1 of 3

to Defendant and in what amount.

INTERROGATORY NO. 4: Did Garnishee have in its possession on or after the

monies, credits, or effects.

INTERROGATORY NO. 5: If Garnishee’s response to Interrogatory No. 1 is not in the

affirmative, please list:

(a) The date Defendant’s employment ended with Garnishee;

his employment ended with Garnishee.

JSJ INVESTMENTS, INC., Plaintiff

By: /s/ Kael K. Bowling_________________________