Free Application for Writ - District Court of Arizona - Arizona

1 MICHAEL ZDANCEWICZ, P.L.L.C. I
2 3550 North Central Avenue, Suite 710 ;
Phoenix, Arizona 85012
3 Phone (602) 266-1327
Facsimile (602) 265-4391
4 Michael Zdancewicz (#12426)
5 [email protected]
Attorneys for Judgment Creditor —
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UNITED STATES DISTRICT COURT
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8 DISTRICT OF ARIZONA
LAWRENCE J. WARPIELD, as Receiver, Case No.; CV 03-2390-PHX-JAT
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.Judgment Creditor, APPLICATION FOR WRIT
U OF GARNISHMENT 7
12 VS, ·
(Earnings) I
I3 MICHAEL ALANIZ; ROBERT CARROLL; et
15 Judgment Debtor s,
16 JOHN HANCOCK LIFE INSURANCE CO.,
11 Garnishee.
18 I am the attorney for the Judgment Creditor in this action and I make this application
19 for issuance ofa Writ of Garnishment, stating the following:
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1 The Judgment Creditor is a party in an action to whom a money judgment has i
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been awarded.: I
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2., The Judgment Creditor has made demand on Robert Carroll (hereafter the §
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24 "Judgment Debtor·") for the payment of the 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- E
exempt portion ofhis wages until the Judgment is satisned.:
3.: .Judgment Debtor owes at least:
Judgment Amounts as to Robert Carroll
Principal: $37,000.:00
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Case 2:03-cv-02390-JAT Document 722 Filed 08/20/2007 Page 1 of 2

1 Prejudgment interest: $12,3 60 .00
2 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
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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5. That Judgment Creditor has not received notice of` the Judgment Debtor’s
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11 intent to enter into an agreement for debt scheduling with `a qualified consumer credit
I2 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, T request that a Writ of Garnishment be issued.,
I6 Dated this ZG day of glfglgéi , 200LZJ
17 MICHAEL ZDANCEWICZ .L.L.C. -
18 Z
19 /s/ Michael Zdance ' z #12426) I
Michael Zdancewicz
20 3550 North Central Avenue, Suite 710
21 Phoenix, Arizona 85012
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Case 2:03-cv-02390-JAT Document 722 Filed 08/20/2007 Page 2 of 2

Case 2:03-cv-02390-JAT

Document 722

Filed 08/20/2007

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Case 2:03-cv-02390-JAT

Document 722

Filed 08/20/2007

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