Free Application for Writ - District Court of Arizona - Arizona

1
2 MICHAEL ZDANCEWICZ, P.L..L.C.
3550 North Central Avenue, Suite 710
3 Phoenix, Arizona 85012
Phone (602) 266-1327
4 Facsimile (602) 265-4391
5 Michael Zdancewicz (#12426)
Michae1@m;pl1c.com
6 Attorneys for Judgment Creditor
`7 UNIIED SIAIES DISIRICI COURI
8 DISIRICI OF ARIZONA
9
10 LAWRENCE J. WARFIELD, as Receiver, Case No.: CV 03-23 90-PHX-JAI
H Judgment Creditor, APPLICATION FOR WRIT
I2 OF GARNISHMENT
vs.
13 (Earnings)
14 MICHAEL ALANIZ; PAIRICK WEI-IRLY
and ANDREA WEI-IRLY; et al ., .
I5
Judgment Debtors,
16
17 AMERICAN INVESTORS LIFE INSURANCE
COMPANY, INC .,
is
Garnishee.
19 V
I am the attorney for the Judgment Creditor in this action and I make this application
20
21 for issuance of a Writ of Garnishment, stating the following:
22 1. Ihe Judgment Creditor is a party in an action to whom a money judgment has
23 been awarded
24 2. The Judgment Creditor has made demand on Patrick Wehrly and Andrea
25 Wehrly (hereafter the “Judgment Debtors") for the payment of the amount adjudged due, but
the Judgment Debtors have not paid that amount and Judgment Debtors have not agreed and
continued to pay the non-exempt portion of their wages mtil the Judgment is satisfied. 3
3. Judgment Debtors owe at least:
Case 2:03-cv-02390-JAT Document 692 Filed 08/20/2007 Page 1 of 2 ’

1 Judgment Amount as to Patrick Wehrly and Andrea Wehrly
2 Principal: $3 9,000 .00
Prejudgment interest: $16,386..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 amotmt 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 of the 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
S made is $79,136.04. _
9 4. That the Garnishee is believed to be an employer of the Judgment Debtor or
10 otherwise owes or will owe to the Judgment Debtor disposable earnings. _
H 5.. That Judgment Creditor has not received notice of the Judgment Debtor(s)
I2 intent to enter into an agreement for debt scheduling with a qualified consumer credit
13 counseling service or, if such notice has been received, that he timely objected in writing, to
14 the ludgment Debtor (s) 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 Garnishment be issued.
17 Dated this I I day of , 200ET
18 MICHAEL DAN nwrcz, . .0
1 3
20 /s Michael Zdance #12426) .
Michael Zdancewicz
21 3550 North Central Avenue, Suite 710 r
22 Phoenix, Arizona 85012
23
24
25
2 .
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Case 2:03-cv-02390-JAT

Document 692

Filed 08/20/2007

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Case 2:03-cv-02390-JAT

Document 692

Filed 08/20/2007

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