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) Q
5 [email protected]
Attorneys for Judgment Creditor `
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UNITED STATES DISTRICT COURT Y
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8 DISTRICT OF ARIZONA
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LAWRENCE J, WARFIELD, as Receiver, Case Nor: CV 03-2390-PPD(-JAT I
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Judgment Creditor, APPLICATION FOR WRIT Q
H or GARNISHMENT j
12 VS-I _
(Earnings)
13 MICHAEL ALANIZ; PATRICK WEHRLY
14 and ANDREA WEHRLY; et al.,
15 Judgment Debtors,
16 LINCOLN BENEFIT LIFE COMPANY,
17 Garnishee.
18 I am the attorney for the Judgment Creditor in this action and I make this application
19 for issuance of a 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. The Judgment Creditor has made demand on Patrick Wehrly and Andrea
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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: _
Jud ment Amount as to Patrick Wehrl and Andrea Wehrly r
Principal: $39,000.00 L
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Case 2:03-cv-02390-JAT Document 694 Filed 08/20/2007 Page 1 of 2

I Prejudgment interest: $ 16,3 86 .00
2 Plus accruing interest on the unpaid principal at the Federal Judgment Rate 5 .05% per
annum from February 28, 2007 until the date of the Writ (August 20, 2007) ($5 40 per day
3 rate x 173 days)in the amount of $934..20
Taxable Costs: $22,283..00
4 Plus accruing interest on Taxable Costs at the Federal Judgment Rate of' 5.05% per
5 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
6 TOTAL AMOUNT DUE as of August 20, 2007 fer which no payment has been
made is $79,136.04.
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4.. That the Garnishee is believed to be an employer ofthe Judgment Debtors or
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otherwise owes or will owe to the Judgment Debtor/s disposable earnings.
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5. That Judgment Creditor has not received notice of the Judgment Debtors intent
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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.
I6 Dated this 1 1 day of` usf , 2003
17 MICHAEL ZDANCE-WICZ, P. .C.
rg WM .2,Qwj
19 /s/ Michael Zdancewic #12426)
Michael Zdancewicz
20 3550 North Central Avenue, Suite 710
21 Phoenix, Arizona 85012
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Case 2:03-cv-02390-JAT

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