Free Application for Writ - District Court of Arizona - Arizona

1 MICHAEL ZDANCEWICZ, P LLC.
2 3550 North Central Avenue, Suite 710
Phoenix, Arizona 85012
3 Phone (602) 266-1327
Facsimile (602) 265-4.391
4 Michael Zdancewicz (#12426)
Michael@)mzpllc.com
5 Attorneys for Judgment Creditor
6
UNITED STATES DISTRICT COURT
7
8 DISTRICT OF ARIZONA
9
LAWRENCE J. WARFIELD, as Receiver, Case No.: CV 03-2390-PI-DQ JAT
10
Judgment Creditor, APPLICATION FOR WRIT
U on GARNISHMENT
12 VS.. ‘
(Earnings)
I3 MICHAEL ALANIZ; PATRICK WEHRLY
14 and ANDREA WEHRLY; et al.,
E5 Judgment Debtors,
16 NORTH AMERICAN COMPANY FOR LIFE
17 AND HEALTH INSURANCE,
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 Patrick Wehrly and Andrea
24 Wehrly (hereafter the “Judgment Debtors”) for the payment of the amount adjudged due, but A
25 the Judgment Debtors have not paid that amount and Judgment Debtors have not agreed and
continued to pay the noneexempt portion of their wages until the Judgment is satisfied.
3. Judgment Debtors owe at least: ‘
‘ J udgjment Amount as to Patrick Wehrly and Andrea Wehrly (
Case 2:03-cv-02390-JAT Document 698 Filed 08/20/2007 Page 1 of 2 A

l Principal: $39,000 .00
2 Prejudgment interest: $16,3 86.00
Plus accruing interest on the unpaid principal at the Federal Judgment Rate 5 .05% per
3 annum from February 28, 2007 until the date of the Writ (August 20, 2007) ($5 .40 per day
rate X 173 days)in the amount of $934 20
4 Taxable Costs: $22,283 .00
5 Plus accruing interest on Taxable Costs at the Federal Judgment Rate of 5.05% per
annum from February 28, 200’7 until the date of the Writ (August 20, 2007) ($3 08 per day
6 rate x 173 days) in the amount of $532 .84
TOTAL AMOUNT DUE as of August 20, 2007 for which no payment has been
7 made is $79,136.04.
8 4.. That the Garnishee is believed to be an employer ofthe .Judgment Debtors or
9 otherwise owes or will owe to the Judgment Debtors disposable earnings.
10 5. That Judgment Creditor has not received notice ofthe Judgment Debtors intent
H to enter into an agreement for debt scheduling with a qualified consumer credit counseling
12 service or, if such notice has been received, that he timely objected in writing, to the
13 Judgment Debtors participation in such an agreement or that he has been notified that the
14
agreement is no longer effective.
15
THEREFORE, I request that a Writ of Garnishment be issued.
16
Dated this [ day of , 200E,J
17 `
18 MICHAEL ZDANCEWICZ .L.L.C..
ra
/s/ Michael Zdan `cz #124 6) _
20 Michael Zdancewic .
3550 North Central Avenue, Suite 710 g
21 Phoenix, Arizona 85012 E
22
23
24 A
25 .·
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Case 2:03-cv-02390-JAT

Document 698

Filed 08/20/2007

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Case 2:03-cv-02390-JAT

Document 698

Filed 08/20/2007

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