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)
5 Michael@,mzpllc.com
Attorneys for Judgment Creditor
6
UNITED STATES DISTRICT COURT I
7 3
8 DISTRICT OF ARIZONA
9 Q
LAWRENCE J. WARPIELD, as Receiver, Case No.: CV 03—2390—PHX-— IAT
l0 Q
Judgment Creditor, APPLICATION FOR WRIT
11 OF GARNISHMENT
12 VS1- f
(Earnings) I
13 MICPLAEL ALANIZ; ROBERT CARROLL; et 1
14 al"’ .
15 Judgment Debtor s,
16 AMERICAN IFIDELIIY LIFE INSURANCE
. CO 1.
17 T
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.. Ihe Judgment Creditor is a party in an action to whom a money judgment has
22 been awarded.
23 2. Ihe .Judg1nent Creditor has made demand on Robert Carroll (hereafter the
21 "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- i
exempt portion of his wages rmtil the Judgment is satisfied.
3. Judgment Debtor owes at least: Q
Case 2:03-cv-02390-JAT Document 719 Filed 08/20/2007 Page 1 of 2 I

I Judgment Amounts as to Robert Carroll
2 Principal: $37,000 00
Prejudgment interest: $12,3 60 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 tiom 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
S 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. A
H 5.. That Judgment Creditor has not received notice of` the .Judgment Debtcr(s) J
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, 1 request that a Writ of Garnishment be issued.
1`7 Dated this day of , 200;%
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20 fs Michael Zdancevvi #12426)
Michael Zdancewicz
21 3550 North Central Avenue, Suite 710
22 Phoenix, Arizona 850l2
24
25 j
2 J
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Case 2:03-cv-02390-JAT

Document 719

Filed 08/20/2007

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Case 2:03-cv-02390-JAT

Document 719

Filed 08/20/2007

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