Free Application for Writ - District Court of Arizona - Arizona

I 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) E
5 [email protected] T
Attorneys for Judgment Creditor -.
6 1
UNITED STATES DISTRICT COURT
8 DISTRICT OP ARIZONA
9
LAWRENCE I. WARFIELD, as Receiver, Case No.: CV 03-2390-PHX-JAT Q
10
Judgment Creditor, APPLICATION FOR WRIT
11 on GARNrsHMENT
12 VS1 _
(Earmrrgs) 3
13 MICHAEL ALANIZ; PATRICK WET-IRLY f
14 and ANDREA WEHRLY; et al., *
15 Judgment Debtors,
I6 PACIFIC LIFE INSURANCE CO.,
ll 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:
20 i
1.. The Judgment Creditor is a party in an action to whom a money judgment has
21 ?
been awarded. Q
22 I
2. The Judgment Creditor has made demand on Patrick J. Wehrly and Andrea
24 Wehrly (hereafter the ".Judgment Debtors") for the payment ofthe amount adjudged due, but
25 the Judgment Debtors have not paid that amount and Judgment Debtors have not agreed and
continued to pay the non—exempt portion oftheir wages until the Judgment is satisfied.
3. Judgment Debtors owe at least:
r §
Case 2:03-cv-02390-JAT Document 699 Filed 08/20/2007 Page 1 of 2 I

I Judgment Amount as to Patrick Wehrly and Andrea Wehrly
2 Principal: $3 9,000 .00
Prejudgment interest: $16,3 86 .00
3 Plus accruing interest on the unpaid principal at the Federal .Judgment Rate 5.05% per
annum from February 28, 2007 until the date ofthe Writ (August 20, 2007) ($5 .40 per day
4 rate x 173 days)in the amount of $934.20
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 amomit of $532..84
7 TOTAL AMOUNT DUE as of August 20, 2007 for which 110 payment has been
S made is $79,136.04.
9 4. That the Garnishee is believed to be an employer ofthe Judgment Debtors or
10 otherwise owes or will owe to the Judgment Debtors disposable earnings.
ll 5. That Judgment Creditor has not received notice of the Judgment Debtors intent
I2 to enter into an agreement for debt scheduling with a qualified consumer credit counseling
lg, service or, if such notice has been received, that he timely objected in writing, to the
14 Judgment Debtors 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 Garnishrnent be issued.
rv Dated this day Or usf , 200QT
18 MIC L zo c wrcz, 1> .c. I
19 Q
l` M
20 /s Michael Zdance #12426)
Michael Zdancevvicz
21 3550 North Central Avenue, Suite 710
22 Phoenix, Arizona 85012
23 I
24
25
-
Case 2:03-cv-02390-JAT Document 699 Filed 08/20/2007 Page 2 of 2 ,

Case 2:03-cv-02390-JAT

Document 699

Filed 08/20/2007

Page 1 of 2

Case 2:03-cv-02390-JAT

Document 699

Filed 08/20/2007

Page 2 of 2