Free Application for Writ - District Court of Arizona - Arizona

1 MICHAEL ZDANCEWICZ, P. L .L.C. .
2 35 50 North Central Avenue, Suite 710
Phoenix, Arizona 85012 _
3 Phone (602) 266-1327
Facsimile (602) 265-4391 j
4 Michael Zdancewicz (#12426)
[email protected]
5 Attorneys for Judgment Creditor `
6
UNITED STATES DISTRICT COURT
7 L
8 DISTRICT OP ARIZONA
9
LAWRENCE- J. WARE IELD, as Receiver, Case No.: CV 03-2390-PHX-JAT
10 .
Judgment Creditor, APPLICATION FOR WRIT ·
H or GARNISHMENT ,
12 VS. • E
(Earnings)
13 MICHAEL ALANIZ; ROBERT CARROLL; et
14 611.,,
15 Judgment Debtors,
16 PENN TREATY NETWORK AMERICA
17 INSURANCE CO.,
18 Garnishee.
19 I am the attorney for the Judgment Creditor in this action and T make this application
20 for issuance of a Writ offiarnishment, 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 ag eed and continued to pay the non- i
exempt portion ofhis wages until the Judgment is satisfied.
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1
3.. Judgment Debtor owes at least:
2 Judgment Amounts as to Robert Carroll
3 Principal: $37,000.00
A Prejudgment interest: $12,360 00
4 Plus accruing interest on the unpaid principal at the Federal Judgment Rate of 5 .05%
per annum from February 28, 2007 until the date of the Writ (August 20, 2007) ($5 .12 per day
5 rate x 173 days) in the amount of $885 .76
6 Taxable Costs: $22,283.00 _
Plus accruing interest on Taxable Costs at the Federal Judgment Rate of 5.05% per 2
7 annum from February 28, 20017 until the date ofthe Writ (August 20, 2007) ($3.08 per day ?
rate x 173 days) in the amount of $532.84
8 TOTAL AMOUNT DUE as of August 20, 2007 for which no payment has been
9 made is $73,061,60,
10 4.. That the Garnishee is believed to be an employer ofthe Judgment Debtor or
11 otherwise owes or will owe to the Judgment Debtor disposable earnings.
12 5. That .Judgment Creditor has not received notice of the Judgment Debtor’s .
13 intent to enter into an agreement for debt scheduling with a qualified consumer credit
14 counseling service or, if such notice has been received, that he timely objected in writing, to J
15 the .Judgment Debtor’s participation in such an agreement or that he has been notified that the
16 agreement is no longer effective.
17 THEREFORE, I request that a Writ of Garnishment be issued.
18 Dated this day of [71/Q , 200}
19 rvrrcrmer ZDANG rw ,19 .L.c
20 ` »
777%%//
21 /s Michael Zdance cz #12426)
22 Michael Zdancewi
3550 North Central venue, Suite 710
23 Phoenix, Arizona 85012 *
24
25
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Case 2:03-cv-02390-JAT

Document 729

Filed 08/20/2007

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Case 2:03-cv-02390-JAT

Document 729

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