Free Application for Writ - District Court of Arizona - Arizona

I MICILAEL ZDANCEWICZ, P .L.L.C.
2 3550 North Central Avenue, Suite 710
Phoenix, Arizona 85012 Q
3 Phone (602) 266-1327
Facsimile (602) 265-4391 {
4 Michael Zdancewicz (#12426)
5 Michaeirgggpt llc.com
Attorneys for Judgment Creditor A
6 Q
UNITED STATES DISTRICT COURT s
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8 DISTRICT OF ARIZONA
LAWRENCE J. WARFIELD, as Receiver, Case No.: CV 03-2390-PHX-.JAI Q
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Judgment Creditor, APPLICATION FOR WRIT *
U on GARNISHMENT .
vs. _
12 (Earnings)
13 MICHAEL ALANIZ; ROBERT CARROLL; et
M al.,
{5 Judgment Debtors,
16 JOHN ALDEN LIFE INSURANCE CO.,
U Garnishee.
18 I am the attorney for the Judgment Creditor in this action and I make this application Q
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
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been awarded.
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2.. Ihe Judgment Creditor has made demand on Robert Carroll (hereafter the ¥
23 j
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: _
Judgment Amounts as to Robert Carroll
Principal: $3 7,000 .00
Case 2:03-cv-02390-JAT Document 717 Filed 08/20/2007 Page 1 of 2

I Prejudgment interest: $12,360.00
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
annum from February 28, 2007 until the date of the Writ (August 20, 2007) ($3 .08 per day
5 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 ofthe 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 ofthe Judgment Debtor’s i
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H intent to enter into an agreement f`or debt scheduling with a qualified consumer credit E
12 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, 1 request that a Writ of Garnishment be issued.
16 Dated this day of giigrg , 200}
17 MICHAEL ZQNCEWICZ, P. . .C.
it W4
19 /s/ ichael Zdaneew` #12426 g
Michael Zdancewicz Q
20 3550 North Central Avenue, Suite 710
21 Phoenix, Arizona 85012
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24
25 A
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Case 2:03-cv-02390-JAT Document 717 Filed 08/20/2007 Page 2 of 2 ]

Case 2:03-cv-02390-JAT

Document 717

Filed 08/20/2007

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Case 2:03-cv-02390-JAT

Document 717

Filed 08/20/2007

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