Free Application for Writ - District Court of Arizona - Arizona

I MICHAEL ZDANCEWICZ, PIL LC.
2 3550 North Central Avenue, Suite 710
Phoenix, Arizona 85012 E
3 Phone (602) 266-1327 {
Facsimile (602) 265-4391
4 Michael Zdancewicz (#12426)
5 [email protected]
Attorneys for Judgment Creditor `_
6 i
UNITED STATES DISTRICT COURT
_ 7 j
S DISTRICT OF ARIZONA
9
" LAWRENCE J. WARFIELD, as Receiver, Case Noi.: CV 03-2.390-PI-IX-IAT
10
Judgment Creditor, APPLICATION FOR WRIT
H OF GARNISHMENT i
12 VS., ‘ ;
(Earnings) I
I3 MICHAEL ALANIZ; ROBERT CARROLL; et
14 al.,
15 Judgment Debtors,
16 STANDARD LIFE INSURANCE CO, OP
17 INDIANA,
18 Garnishee.
19 I am the attorney for the Judgment Creditor in this action and I make this application
20 for issuance ofa 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 “Iudgment 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:
1
Case 2:03-cv-02390-JAT Document 728 Filed 08/20/2007 Page 1 of 2

I 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 fr·om 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 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
8 made is $73,061.60,
9 4. That the Garnishee is believed to be an employer ofthe Judgment Debtor or
10 otherwise owes or will owe to the Judgment Debtor disposable earnings.
11 5.. That Judgment Creditor has not received notice of the Judgment Debtor’s
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,
16 THEREFORE, I request that a Writ of Garnishment be issued. .
rv mama this 2.0 day of g·L>yw+ ,200_/T7
18 ivrronnsr znrmcawrc , L.L.C.
l
20 /s/ Michael Zdanc `cz #1242
Michael Zdancewi
21 3550 North Central Avenue, Suite 710
22 Phoenix, Arizona 85012 `
24
25 ;_
2 J T
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Case 2:03-cv-02390-JAT

Document 728

Filed 08/20/2007

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Case 2:03-cv-02390-JAT

Document 728

Filed 08/20/2007

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