Free Application for Writ - District Court of Arizona - Arizona

I MICHAEL ZDANCEWTCZ, 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) Q
5 Michael@m;p11c.coni
Attorneys for Judgment Creditor
6
UNITED STATES DISTRICT COURT
8 DISTRICT OF ARIZONA —
9
LAWRENCE J. WARP IELD, as Receiver, Case No .: CV 03-2390-PHX-JAT ‘
10 I
Judgment Creditor, APPLICATION FOR WRIT
11 or GARNISHMENT ;
vs. ?
12 (Earnings)
13 MICHAEL ALANIZ; ROBERT CARROLL; et
14 al.,
15 Judgment Debtors,
16 PACIP ICARE LIFE AND HEALTH
17 INSURANCE CO., Q
18 Garnishee.
19 I am the attorney for the Judgment Creditor in this action and I make this application I
20 for issuance ofa Writ ofGarnishment, stating the following:
21 1. The Judgment Creditor is a party in an action to whom a money judgment has
22 been awarded.
23 2. The Judgment Creditor has made demand on Robert Carroll (hereafter the
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 of his Wages until the Judgment is satisfied.
3. Judgment Debtor owes at least: Q
Case 2:03-cv-02390-JAT Document 732 Filed 08/21/2007 Page 1 of 2

1 Judgment Amounts as to Robert Carroll
2 Principal: $37,000 00
Prejudgment interest: $12,360.00
3 Plus accruing interest on the unpaid principal at the Federal Judgment Rate of 5 .05%
per annum Brom February 28, 2007 until the date ofthe Writ (August 20, 2007) ($5..12 per day
4 rate X 173 days) in the amount of $885.76
5 Taxable Costs: $22,283 .00
Plus accruing interest on Taxable Costs at the Federal Judgment Rate of 5.05% per
6 annum from February 28, 200‘7 until the date ofthe Writ (August 20, 2007) ($3 08 per day
rate x 173 days) in the amount of $532.84
7 TOTAL AMOUNT DUE as of August 20, 2007 for which no payment has been
S made is $73,061.60. j
9 4. That the Garnishee is believed to be an employer of the Judgment Debtor or
10 otherwise owes or will owe to the Judgment Debtor disposable earnings.
H 5. That Judgment Creditor has not received notice ofthe Judgment Debt0r·(s)
12 intent to enter into an agreement for debt scheduling with a qualified consumer credit T
13 counseling service or, if such notice has been received, that he timely objected in writing, to j
14 the Judgment Debtor(s) participation in such an agreement or that he has been notified that the
15 agreement is no longer effective.
16 THEREFORE, I request that a Writ of Garnishment be issued.
17 Dated this Zi day of @{3,,;+ , 200}
18 MICHAEL ZDANCEWICZ, P.L.L.C.
19 VE}
20 /s/ Michael Zd 'cz #1 426)
Michael Zdance
21 3550 North Central Avenue, Suite 710 *
22 Phoenix, Arizona 85012 1
23
24
25
2 1
Case 2:03-cv-02390-JAT Document 732 Filed 08/21/2007 Page 2 of 2

Case 2:03-cv-02390-JAT

Document 732

Filed 08/21/2007

Page 1 of 2

Case 2:03-cv-02390-JAT

Document 732

Filed 08/21/2007

Page 2 of 2