When writing your motion for turnover and appointment of receiver,
please use the followng pragraphs for my nomination
Receiver: Plaintiff further moves the Court to appoint a receiver pursuant to
§31.002(b)(3) Id., to take possession of the nonexempt assets and documents related to
the assets, sell the assets and apply the proceeds from the sale towards the judgment, and the
receiver’s fee and costs. Plaintiff requests this court appoint Tony Savarese, whose address
is 3708 East 29th Street Suite 315, Bryan TX 77802 (telephone number (979) 227-7727, fax (877)
665-6742, receiver@xr2.us) as Receiver. Mr. Savarese has been enforcing civil money judgments
thru judicial proceedings since 2013. He has a collectors bond on file with the Texas Secretary of
State. Collecting this judgment is going to be primarily an investigative task. Mr.
Savarese is a licensed private investigator, and has been appointed in other District Courts of
Dallas, Tarrant, Collin, Ellis and Harris Counties. Mr. Savarese is perfectly suited for this
task.
Receiver's Bond: Plaintiff requests no bond be required. "There is a strong view
that since the underlying obligation has been determined by final judgment, the judgment debtor will
not be harmed if no bond, or merely a nominal bond, is required ... any bond required should not be
in an amount that would act as a prohibitive cost or make it economically impossible for the
judgment creditor to use the remedies provided in [the turnover statute] for even the smallest of
judgments." Childre v. Great Sw. Life Ins. Co., 700 S.W. 2d 284, 289 (Tex. App.—Dallas
1985, no writ).
Receiver's Fee: The Receiver's Fee should be the customary 25% and taxed against
the Judgment Debtor. The Receiver's actual expences should also be taxed against the judgment
debtor, subject to the courts approval.