Free Application for Writ - District Court of Arizona - Arizona

1 MICHAEL ZDANCEWICZ, PLL C.
2 3550 North Central 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
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UNITED STATES DISTRICT COURT
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8 DISTRICT OP ARIZONA
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LAWRENCE J WARFIELD, as Receiver, Case No.: CV 03-2390-PI—IX-JAT §
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Judgment Creditor, APPLICATION FOR WRIT
1* or GARNISHMENT
12 VS. ‘ Q
(Earnings)
I3 MICHAEL ALANIZ; PATRICK WEHRLY I
14 and ANDREA WEHRLY; et al .,
15 Judgment Debtors, _
16 AMERUS LIFE INSURANCE. CO .,
17 Garnishee.
18 I am the attorney for the Judgment Creditor in this action and I make this application
19 for issuance ofa Writ of`Garnish1nent, 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 avvar ded.
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2. The Judgment Creditor has made demand on Patrick Wehrly and Andrea
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24 Wehrly (hereafter the "Iudgment Debtors") for the payment of the 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 rmtil the Judgment is satisfied.
l 3. Judgment Debtors owe at least:
Jud ent Amount as to Patrick Wehrl and Andrea Wehrly —
Principal: $3 9,000.00 U
I l E
Case 2:03-cv-02390-JAT Document 691 Filed 08/20/2007 Page 1 of 2 I

1 Prejudgment interest: $16,386.00
2 Plus accruing interest on the unpaid principal at the Federal Iudgment 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 Iudgment 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 for 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 Iudgrnent Debtors or
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otherwise owes or will owe tc the Judgment Debtors disposable earnings
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5. That Judgment Creditor has not received notice ofthe Iudgment 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.
16 Dated this I (ny cf [iv @[03+ ,2003
17 MICHAEL ZDANCEW CZ, P L.
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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

Document 691

Filed 08/20/2007

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Case 2:03-cv-02390-JAT

Document 691

Filed 08/20/2007

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