Contract analysis

I. CERTIFICATE OF LAST KNOWN ADDRESSES Pursuant to Rule 239a of the Texas Rules of Civil Procedure, Plaintiff hereby certifies the last known mailing addresses of each Defendant in this action. Plaintiff has exercised due diligence in ascertaining the addresses set forth below and believes them to be the current and correct mailing addresses for each Defendant as of the date of this filing. A. Ridgeline Freight Carri

II. CERTIFICATE REGARDING SERVICE OF PROCESS A. Service on Gerald "Gerry" Brashear Plaintiff's Original Petition in this action was filed with the Clerk of the 134th Judicial District Court of Dallas County, Texas on February 12, 2024. On February 14, 2024, citation was duly issued by the Clerk of the Court for Defendant Gerald "Gerry" Brashear, directed to his last known address at 2314 Quail Creek Drive, Edmond, Ok

III. CERTIFICATE REGARDING DEFENDANTS' FAILURE TO ANSWER A. Answer Deadline for Gerald "Gerry" Brashear Defendant Gerald "Gerry" Brashear was personally served with Plaintiff's Original Petition and citation on February 22, 2024, as described in Section II.A above and as evidenced by the return of service attached hereto as Exhibit A. Pursuant to Rules 99 and 101 of the Texas Rules of Civil Procedure, a defendant who

IV. STATEMENT REGARDING MILITARY SERVICE Pursuant to the Servicemembers Civil Relief Act, 50 U.S.C. §§ 3901 et seq. (the "SCRA"), Plaintiff is required to file a declaration or affidavit regarding the military service status of any individual defendant against whom a default judgment is sought. With respect to Defendant Gerald "Gerry" Brashear, Plaintiff states upon information and belief, based upon a review of the

V. REQUEST FOR ENTRY OF DEFAULT Based on the foregoing representations and certifications, Plaintiff Stonefield Logistics Group Inc. respectfully requests that the Clerk of the 134th Judicial District Court of Dallas County, Texas, enter default against both Defendants in this action, as follows:

1. Ridgeline Freight Carriers LLC — Plaintiff requests that the Clerk enter default against Defendant Ridgeline Freight Carriers LLC for its failure to file an answer or any other responsive pleading by the applicable deadline of March 27, 2024. Ridgeline was duly served with process through the Texas Secretary of State on February 26, 2024, and has wholly failed to answer, appear, or otherwise respond in this action

2. Gerald "Gerry" Brashear, Individually — Plaintiff requests that the Clerk enter default against Defendant Gerald "Gerry" Brashear, individually, for his failure to file an answer or any other responsive pleading by the applicable deadline of March 18, 2024. Brashear was personally served with process on February 22, 2024, at his residence in Edmond, Oklahoma, and has wholly failed to answer, appear, or otherwise r

VI. PRAYER WHEREFORE, PREMISES CONSIDERED, Plaintiff Stonefield Logistics Group Inc. respectfully requests that the Clerk of the 134th Judicial District Court of Dallas County, Texas, enter default against Defendant Ridgeline Freight Carriers LLC and Defendant Gerald "Gerry" Brashear, individually, for their respective failures to timely answer or otherwise appear in this cause, and that upon entry of such default, P

1. The statements contained in the foregoing Certificate of Last Known Address of Defendants and Request for Entry of Default are true and correct to the best of my knowledge, information, and belief.

2. The addresses set forth in Section I of the foregoing Certificate are, to the best of my knowledge, information, and belief, the last known mailing addresses for each Defendant.

3. I have personally reviewed the official docket and filing records maintained by the Clerk of the 134th Judicial District Court of Dallas County, Texas for Cause No. DC-24-01847 and confirm that, as of the date of this declaration, neither Defendant Ridgeline Freight Carriers LLC nor Defendant Gerald "Gerry" Brashear has filed an answer, responsive pleading, appearance, motion for extension of time, or any other do

4. Based upon a review of the United States Department of Defense Manpower Data Center records, I am informed and believe that Defendant Gerald "Gerry" Brashear is not currently serving in the military service of the United States.

5. The returns of service and certificates of service attached hereto as Exhibits A and B are true and correct copies of the documents received by counsel for Plaintiff. I declare under penalty of perjury that the foregoing is true and correct. Executed on April 2, 2024, in Dallas, Dallas County, Texas. ________________________________________ Jeffrey Park State Bar No. 24112785 Calderwood & Harkness LLP 2200 Ross Av