Free Application for Writ - District Court of Arizona - Arizona

1 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) Q
5 Michael@m;pllc.com ' j
Attorneys for Judgment Creditor
6 Q
UNITED STATES DISTRICT COURT
A7 2
8 DISTRICT OF ARIZONA
LAWRENCE J. WARFIELD, as Receiver, Case No.: CV 03-2390-PHX- JAT
l0 E
Judgment Creditor, APPLICATION FOR WRIT i
*1 on GARNISHMENT A
vs. I
12 (Earnings) _
13 MICHAEL ALANIZ; ROBERT CARROLL; et
14 air 5
15 Judgment Debtors,
I6 NORTH AMERICAN COMPANY F OR LIFE
17 AND HEALTH INSURANCE,
18 Garnishee.
19 I am the attorney for the Judgment Creditor in this action and I make this application
20 for issuance of a Writ of Garnishment, 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 L. 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 ofhis wages until the Judgment is satisfied.
3. Judgment Debtor owes at least:
1
Case 2:03-cv-02390-JAT Document 730 Filed 08/20/2007 Page 1 of 2

1 Judgment Amounts as to Robert Carroll
2 Principal: $37,000,00
Prejudgment inter est: $12,360 ,00
3 Plus accruing interest on the unpaid principal at the Federal Judgment Rate of 5 ,05%
per annum from 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, 2007 until the date of the 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
8 made is $73,061.60.
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 of the Judgment Debt0r’s l
12 intent to enter into an agreement for debt scheduling with a qualified consumer credit
13 counseling service or, if such notice has been received, that he timely objected in writing, to
14 the Judgment Debtor’s participation in such an agreement or that he has been notified that the
15 agreement is no longer effective., T
16 THEREFORE., I request that a Writ of Garnishrnent be issued.,
17 Dated this Z0 day of { 3 ,200Z-i
18 MTC L ZDA CFLW L.L.C.
19 Jjlaéj
20 /s/ Michael Zd z #12426) I
Michael Zdancewicz
2] 3550 North Central Avenue, Suite 710 j
22 Phoenix, Arizona 85012 E
24
· 25
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