Free Application for Writ - District Court of Arizona - Arizona

I MICHAEL ZDANCEWICZ, P.L.L.C.
2 3550 North Central Avenue, Suite 710
Phoenix, Arizona 85012
3 Phone (602) 266-1327
Facsimile (602) 265-4391
4 Michael Zdancewicz (#12426) _
5 Michael(@£mzpllc.com I
Attorneys for Judgment Creditor
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UNITED STATES DISTRICT COURT
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8 DIS IRICT Oli ARIZONA
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LAWRENCE I. WARFIELD, as Receiver, Case No.: CV 03—2390—PHX-JAT q
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Judgment Creditor, APPLICATION FOR WRIT
H on GARNISHMENT
12 VS. ·
(Earnings)
13 MICHAEL ALANIZ; ROBERT CARROLL; et
15 Judgment Debtors,
16 AMERICAN NATIONAL INSURANCE CO.,
17 Garnishee.
18 I am the attorney for the Judgment Creditor in this action and I make this application
19 for issuance ofa Writ ofGarnislunent, stating the following:
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1.. The Judgment Creditor is a party in an action to whom a money judgment has
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been awarded.
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2. The Judgment Creditor has made demand on Robert L. Carroll (hereafter the
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24 "Judgment Debtor”) for the payment ofthe amount adjudged due, but the Judgment Debtor
25 has not paid that amount and Judgment Debtor has not agreed and continued to pay the non-
exempt portion ofhis wages until the Judgment is satisfied.
3. Judgment Debtor owes at least: .
Judgment Amounts as to Robert Carroll i
Principal: $317,000.00 .
Case 2:03-cv-02390-JAT Document 734 Filed 08/21/2007 Page 1 of 2 j

1 Prejudgment interest: $12,360.00
2 Plus accruing interest on the unpaid principal at the Federal Judgment Rate of` 5-05%
per amrum from February 28, 2007 until the date ofthe Writ (August 20, 2007) ($5 .12 per day
3 rate x 173 days) in the amount of $885 76
Taxable Costs: $22,283 .00
4 Plus accruing interest on Taxable Costs at the Federal Judgment Rate of 5.05% per
5 annum from February 28, 2007 until the date of the Writ (August 20, 2007) ($3 .08 per day
rate x 173 days) in the amount of $532 .84
6 TOTAL AMOUNT DUE as of August 20, 2007 for which no payment has been
made is $73,061.60.
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4. That the Garnishee is believed to be an employer of the Judgment Debtor or
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otherwise owes or will owe to the Judgment Debtor disposable earnings.
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10 5. That Judgment Creditor has not received notice of the .Judgment Debtor’s
11 intent to enter into an agreement for debt scheduling with a qualified consumer credit
12 counseling service or, if such notice has been received, that he timely objected in writing, to
13 the Judgment Debtor/’s participation in such an agreement or that he has been notified that the
14 agreement is no longer effective.
15 THEREFORE, I request that a Writ of Garnishment be issued.
I6 Dated this Z ( day of V3 T, , 200_7`
17 MICHAEL ZDANCEWICZ, P.L. .
18 53/4/
19 /s/ Michael Zdancewi 12426) ‘
Michael Zdancewicz
20 3550 North Central Avenue, Suite 710
21 Phoenix, Arizona 85012
22 n
23 I
24 Z
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Case 2:03-cv-02390-JAT

Document 734

Filed 08/21/2007

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Case 2:03-cv-02390-JAT

Document 734

Filed 08/21/2007

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