If you are a litigator at another firm, a solo, a small-firm civil litigator, a transactional lawyer who took a litigation matter to judgment because your client asked, or in-house counsel without internal collections capacity, you may have landed somewhere familiar: you have won, your client is owed money, and the next phase is post-judgment enforcement work that simply is not your practice.
We take referrals and co-counsel with outside lawyers on collections matters. We have handled commercial collections in Texas since 1994, and today we have 15 lawyers whose practice covers the full range of collections work: pre-suit demand, litigation, post-judgment discovery, garnishment, turnover orders, contempt proceedings, foreign judgment registration, appeal-period collection, and net-worth-affidavit challenges.
This page lays out how we work with referring counsel and what to expect when you bring us a matter.
The Referral and Co-Counsel Relationship
Our working principles for referrals and co-counsel arrangements are simple and consistent.
Collections only. Collections is our practice. We do not solicit family, transactional, employment, or general commercial work from clients of referring counsel. The relationship between the client and the referring lawyer stays intact, and when the collection matter wraps up, the client goes back to you for everything else.
Clear fee arrangements. We structure referral and co-counsel engagements to comply with Texas Disciplinary Rule of Professional Conduct 1.04(f), which governs the division of fees between lawyers not in the same firm. We document the fee-sharing arrangement at the outset, disclose it to the client in writing, and get the client’s approval. We work with several structures, including referral fees on a percentage basis, co-counsel arrangements with proportional fee division, and hourly engagements with a separate referral fee, depending on your preference and the nature of the matter.
Transparent communication. We keep you informed of significant developments. How involved you stay is your call: some referring lawyers want pass-through copies of every filing, others want milestone-only updates, and we accommodate either.
Defined handoff. When a matter comes in, we agree with you at intake on the scope of our work, the role (if any) you continue to play, the communication cadence, and the handoff back to you at conclusion.
Matters We Regularly Take by Referral
Our referral docket includes:
Post-judgment enforcement on judgments obtained by referring counsel. This is the most common referral. You prosecuted the underlying matter, obtained a judgment, and the client is asking what comes next. We take the file at that point and run full enforcement: abstracts, post-judgment discovery, depositions, writs of garnishment, writs of execution, turnover orders, receivership, and contempt proceedings where it takes that.
Foreign judgment domestication. A lawyer in another state has a judgment for a client whose debtor is in Texas or has Texas assets. We register the judgment under Texas Civil Practice & Remedies Code Chapter 35, defend against any motion to vacate, and run full enforcement.
Texas judgments enforced in other states. We coordinate with counsel in other states to register and enforce Texas judgments where the debtor’s assets have moved out of state.
Collection-on-appeal matters. A judgment is on appeal, and the debtor has filed a net-worth affidavit to reduce the supersedeas bond. You want our accounting and litigation experience to challenge the affidavit. This is something we do well: we have convinced courts to strike net-worth affidavits and have consistently forced debtors to post larger bonds than they claimed were necessary.
Dormant judgment revival. The judgment is approaching or has passed the dormancy threshold. We handle revival and renewal under Texas Civil Practice & Remedies Code §§ 31.006 and 34.001, including writs of scire facias.
Complex collection situations. Multi-state debtors, asset-concealment cases, sophisticated debtors using trusts or layered entities, debtors operating across state lines, and matters where the debtor has already defeated less sophisticated collection efforts.
Suits on notes and guaranties referred from transactional or banking lawyers. Lawyers whose practice is loan documentation rather than enforcement litigation regularly refer the litigation phase.
Post-Judgment Enforcement Scope for Lawyers
Our post-judgment enforcement work covers the full Texas toolkit. For referring lawyers who want to judge whether our depth matches the matter, here are the relevant tools and authorities:
Post-judgment discovery under Texas Rule of Civil Procedure 621a, including interrogatories, requests for production, requests for disclosure, and post-judgment depositions on oral or written questions. We use written discovery aggressively and depositions selectively, often using the deposition to test sworn discovery responses against the documents.
Abstracts of judgment under Texas Property Code Chapter 52, recorded in counties where the debtor owns or may own real property, creating a judgment lien on non-exempt real property.
Writs of execution under Texas Civil Practice & Remedies Code Chapter 34 and Texas Rules of Civil Procedure 621–629, directing the sheriff or constable to seize and sell non-exempt personal property.
Writs of garnishment under Texas Civil Practice & Remedies Code Chapter 63, served on banks, account debtors of the judgment debtor, and other third parties holding the debtor’s property or owing the debtor money. Texas exempts current wages from garnishment for ordinary commercial debts, so we garnish bank accounts, receivables, and other non-wage property rather than the debtor’s employer.
Turnover orders under Texas Civil Practice & Remedies Code § 31.002, used to compel the debtor to turn over non-exempt property, including property that is hard to reach by ordinary execution, such as interests in other entities, accounts receivable, intellectual property, and contractual rights.
Receivership under § 31.002 and our regular receivership counsel, used where a court-appointed receiver can manage or liquidate property more effectively than the debtor will.
Contempt proceedings for debtors who fail to comply with court orders, including failure to comply with post-judgment discovery, turnover orders, or deposition subpoenas. We have secured contempt findings, body attachments, and incarcerations of recalcitrant debtors.
Appeal-period enforcement. Where the debtor appeals but does not properly supersede the judgment, enforcement continues. We have experience with both the substantive and procedural sides of supersedeas under Texas Rule of Appellate Procedure 24, including challenges to net-worth affidavits filed under the alternative bond procedures.
Distinctive Capabilities
A few capabilities set our collections practice apart and matter most to referring counsel deciding where to send a matter.
Net-worth affidavit challenges. When a debtor on appeal files a net-worth affidavit under Texas Rule of Appellate Procedure 24.2(c) to reduce the supersedeas bond, we have the accounting depth to challenge it. We have convinced trial courts to strike net-worth affidavits entirely and have consistently forced debtors to post larger bonds than they claimed were necessary. That is not a common capability among Texas collections firms.
Asset investigation. We combine post-judgment discovery, public-records research, and third-party subpoena practice to find assets the debtor has not disclosed. Where the debtor has used trust structures, layered entities, or out-of-state holdings to hide assets, our experience is direct.
Multi-state coordination. We regularly work with counsel in other states on both inbound matters (a foreign judgment registered in Texas) and outbound matters (a Texas judgment enforced elsewhere).
Receivership and turnover practice. Receivership is underused by general practitioners. We use it where it makes sense and have working relationships with receivers experienced in collection-context appointments.
What the Firm Doesn’t Do
For referring lawyers sizing up the fit, it helps to be plain about what we do not handle.
We do not handle:
- The underlying litigation prior to judgment (unless the entire matter is referred from intake)
- Bankruptcy filings or bankruptcy litigation as bankruptcy counsel; we coordinate with bankruptcy counsel instead
- Family law, estate, real estate transactional, employment, or general commercial work
- Defense work outside the collection context
For matters with components outside our practice, we coordinate with you or other specialists. Our interest is in the collections matter; we do not go after the client’s other legal needs.
How to Refer a Matter
When you are ready to bring a matter to us, the practical steps are:
- Initial conversation. Usually a 15- to 30-minute call between you and one of our lawyers to discuss the matter, the issues we expect, and fit.
- Engagement structure. We agree on the engagement structure (referral fee, co-counsel, full handoff) and the fee arrangement, documented in writing.
- Client engagement. We sign a written engagement letter with the client. Where Rule 1.04(f) requires it, the engagement letter includes the disclosure of the fee-sharing arrangement and the client’s written consent.
- File transfer. You provide the matter file. For post-judgment matters, we typically need the judgment, the petition and answer, key trial exhibits relating to the debtor’s identity and finances, any prior post-judgment work, the abstract (if any), and the file’s correspondence.
- First substantive action. Usually within 7 to 14 days of engagement, depending on the matter.
Make the Referral
If you have a matter that needs collections counsel, a judgment that needs enforcement, a foreign judgment that needs Texas domestication, a note-and-guaranty matter that needs litigation, or a complex collection situation that has stalled, get in touch. Initial referral conversations are without obligation.
Contact us to get started or call 214-368-4686.
Related Pages
- Collecting Judgments in Texas
- Enforcing Foreign Judgments
- Collections While Judgment on Appeal
- Post-Judgment Written Discovery
- Multi-State and Out-of-State Judgment Enforcement
- Reviving a Dormant Judgment
- Texas Collections Law FAQs
Referring Lawyer FAQs
What fee structures does the firm use for referrals?
We structure referrals to comply with Texas Disciplinary Rule 1.04(f). Common structures include a referral fee paid as a percentage of our fee on the matter (with client disclosure and consent), a co-counsel arrangement with proportional fee division, and a flat referral fee on certain matter types. We agree on the structure in writing at the outset.
Will the firm solicit other work from my client?
No. Collections is our practice. We do not solicit family, transactional, employment, or general commercial work from clients of referring counsel. When the collection matter concludes, the client returns to you for everything else.
What if my client wants to discuss the matter directly with me, not the firm?
That is your call. Some referring lawyers want all client communication routed through them; others want us to communicate directly with the client. We accommodate either and confirm the preferred structure at intake.
Can the firm take a partial referral: for example, just the post-judgment enforcement?
Yes. Many of our referrals are for post-judgment work only, with the referring lawyer having handled the matter through judgment. We structure the engagement to cover only the referred portion.
What if the matter requires an appeal?
We handle the appellate work that arises in the post-judgment enforcement context: supersedeas issues, appeals of post-judgment orders, and appeals of judgment-enforcement rulings. For appeal of the underlying judgment itself, we usually coordinate with appellate counsel rather than handle it directly.
How does the firm communicate with referring counsel during the matter?
We set a communication cadence with you at intake: copy on all filings, milestone updates, monthly status reports, or another structure you prefer. By default we copy referring counsel on all substantive filings and provide written status updates as material events occur.
What if the matter involves out-of-state assets or out-of-state debtors?
We register Texas judgments in other states (through coordinating local counsel) and register out-of-state judgments in Texas under Chapter 35. For multi-state matters, we coordinate the strategy and work with counsel in each relevant state.
Does the firm handle creditor representation in bankruptcy?
We do not act as bankruptcy counsel. When a matter goes to bankruptcy, we coordinate with the client's bankruptcy counsel on proof-of-claim filing, non-dischargeability issues, stay-relief, and continued state-court collection against non-bankrupt parties. We know the touchpoints between state-court collection and bankruptcy proceedings well.
Will the firm take small-balance matters?
We evaluate fit matter by matter. Very small matters may not be economic to litigate, and we will say so honestly at intake. We have handled matters across the size spectrum, from small four-figure balances through commercial portfolios in the millions.
Are the firm's lawyers active in bar collections sections or CLE programming?
Our lawyers have presented to bar sections and continuing legal education programs on post-judgment enforcement, supersedeas and net-worth affidavit practice, foreign judgment registration, and related topics. A collections-focused practice has given us substantial subject-matter depth across the firm.