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1. I have been a resident of Texas since XX/XX/XXXX. I have copies of communication between Fendelman & Associates staff member, XXXX XXXX XXXX and my employer, as well as my communication with both parties in response.
2. Fendelman & Associates LLC of XXXX XXXX, Missouri ( to include XXXX XXXX, XXXX ) have obtained a Writ of Garnishment against me in the amount of {$4300.00} ordered XX/XX/XXXX due to an alleged debt I owe to an attorney named XXXX XXXX who I do not know and has never represented me at any time.
3. XXXX XXXX contacted my employer 's XXXX XXXX XXXX representative XXXX XXXX on XX/XX/XXXX by illegally " serving '' XXXX XXXX with the Writ of Garnishment order containing the alleged debt, amount owed, the case number and other information via an unencrypted e-mail.
4. There is reason to believe Fendelman & Associates may have served a " Missouri registered agent '' of XXXX on XX/XX/XXXX, although there is no proof of service.
5. Fendelman & Associates is a law firm which specializes in collections, as stated on their website.
6. XXXX XXXX instructed the payroll representative, XXXX XXXX, to begin garnishing my wages on XX/XX/XXXX for an alleged debt owed to an attorney who never represented me at any time.
7. I have never been, in any way, notified, told, contacted, served with any type of notification or court paperwork indicating a garnishment or debt owed to this entity at any time, until the payroll representative sent me an e-mail at work on XX/XX/XXXX at XXXX stating my wages will be garnished beginning XX/XX/XXXX.
8. Wages are considered exempt from garnishment per Texas law, 9, I called Fendelman & Associates on XX/XX/XXXX around XXXX and spoke with XXXX XXXX XXXX I asked XXXX XXXX what the nature of the debt was, notified her of my phone number and state of residence. XXXX XXXX would not verify the debt and I told her that I do not have any knowledge of this debt and there appears to be an error. I requested to speak with the attorney XXXX XXXX who is the alleged creditor and was denied the ability to do so.
10. The garnishment in question is for alleged fees from XXXX owed to a XXXX XXXX, XXXX XXXX, who has never represented me in any court proceeding at any time and is unknown to me other than her name appearing on the Writ of Garnishment against me.
11. I notified XXXX XXXX. XXXX XXXX and Attorney Fendelman via e-mail on XX/XX/XXXX that their actions and the garnishment was illegal practice via e-mail, to which XXXX XXXX consulted with XXXX XXXX. XXXX XXXX was the only XXXX to respond to my concerns, by notifying me that the garnishment was to take effect as of XX/XX/XXXX.
12. XXXX XXXX demanded XXXX XXXX to send, via e-mail, the interrogatories or answer to the court ( well past the allotted 20 days to file an answer with the court ) via e-mail containing my personal information as well as inaccurate information contained within the order. I have a copy of the e-mails between XXXX XXXX and XXXX XXXX as well as between myself and XXXX XXXX.
13. The name and address on the court order are not correct ; however, XXXX XXXX knew my last name had changed and who my employer was. I find it inexcusable that I was not able to be located for proper, legal service of court proceedings considering I am a tax paying, law-abiding citizen with a driver 's license, professional license and public address which is found with extreme ease by conducting a XXXX search.
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