Free Application for Writ - District Court of Arizona - Arizona

J MICHAEL ZDANCEWICZ, P LLC.
2 3550 North Centra] 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 .
6
UNITED STATES DISTRICT COURT .
7 .
8 DISTRICT OF ARIZONA E
9
LAWRENCE J. WARE IELD, as Receiver, Case No.): CV 03-2390—PHX-JAT
10 -
Judgment Creditor, APPLICATION FOR WRIT
11 on GARMSHMENT
12 VS1 _ 2
(Earmrrgs) j
13 MICHAEL ALANIZ; PATRICK WEHRLY j
14 and ANDREA WEHRLY, et al., j
15 Judgment Debtor s,
16 NATIONAL WESTERN LIPE INSURANCE
CO ,
1 7 {
lg 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,. 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 Wehriy and Andrea
24 Wehrly, (hereafter the "Judgrnent Debtor·s") for the payment ofthe amount adjudged due, but
25 the Judgment Debtors have not paid that amormt and Judgment Debtors have not agreed and
continued to pay the non-exempt portion oftheir wages turtil the Judgment is satisfied, 1
3, Judgment Debtors owe at 1east:
Case 2:03-cv-02390-JAT Document 697 Filed 08/20/2007 Page 1 of 2

I Judgment Amount as t0 Patrick Wehrly and Andrea Wehrly
2 Principal: $3 9,000.00
Piejudgment 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
Taxable Costs: $22,283 .00
5 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 amount of $532.84
7 TOTAL AMOUNT DUE as of August 20, 2007 for which no payment has been
8 made is $79,136.04.
9 4. That the Garnishee is believed to be an employer of the Judgment Debtors or
10 otherwise owes or will owe to the Judgment Debtors disposable earnings.
H 5. That Judgment Creditor has not received notice ofthe .Judgment Debtors intent
12 to enter into an agreement for debt scheduling with a qualified consumer credit counseling
rg 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 T request that a W it of Garnishment be issued
I7 Dated this / i day of [ mf , 200_§;
lg MICHAEL znnncnwroz, r> . .c.
20 /s/ M` ael Zdance ` #12426) I
Michael Zdancewicz j
21 3550 North Central Ave e, Suite 710 .
22 Phoenix, Arizona 85012 ’
23
24
25
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Case 2:03-cv-02390-JAT

Document 697

Filed 08/20/2007

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Case 2:03-cv-02390-JAT

Document 697

Filed 08/20/2007

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