Free Application for Writ - District Court of Arizona - Arizona

I MICHAEL ZDANCEWICZ, P L .L C, Z
2 3550 North Central Avenue, Suite 710 {
Phoenix, Arizona 85012 j
3 Phone (602) 266-1327
Facsimile (602) 265-4391 . ?
4 Michael Zdancewicz (#12426)
5 [email protected]
Attorneys for Judgment Creditor Q
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UNITED STATES DISTRICT COURT §
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S DISTRICT OF ARIZONA
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LAWRENCE .J. WARFIELD, as Receiver, Case No : CV 03—2390—PHX- JAT
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Judgment Creditor, APPLICATION FOR WRIT
H or GARNISHMENT I
12 VS, - l
(Earmngs) j
13 MICHAEL ALANIZ; PATRICK WEHRLY
14 and ANDREA WEHRLY; et al., ¥
15 Judgment Debtor s,
16 OM FINANCIAL 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 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. j
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2. The Judgment Creditor has made demand against Patrick Wehrly and Andrea g
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24 Wehrly (hereafter the "Judgrnent 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. j
3. Judgment Debtors owe at least:
J udgrg ent Amount as to Patrick Wehrly and Andrea Wehrly g
Principal: $3 9,000 .00
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Case 2:O3—cv-O2390—JAT Document 688 Filed O8/20/2007 Page 1 of 2

1 Prejudgrnent interest: $16,386 00
Plus accruing interest on the unpaid principal at the Federal Judgment Rate of 5.05%
2 per annum from February 28, 2007 until the date ofthe 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
annum from February 28, 2007 until the date ofthe Writ (August 20, 2007) ($3.08 per day
5 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 Judgment Debtors or
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otherwise owes or will owe to the Judgment Debtors disposable earnings.
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5. That Judgment Creditor has not received notice ofthe .Judgment Debtor(s)
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H intent to enter into an agreement for debt scheduling with a qualified consumer credit
12 counseling service or, if such notice has been received, that he timely objected in writing, to
B the Judgment Debtor·(s) participation in such an agreement or that he has been notified that the
14 agreement is no longer effective.
15 THEREFORE, 1 request that a Writ ofGa1nishment be issued.
16 Dated this Z0 day Or /2/cl tgt , 200}
17 MICHAEL ZDANCEWICZ, C.
rs
19 /s/ Michael Zdanc #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 688

Filed 08/20/2007

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Case 2:03-cv-02390-JAT

Document 688

Filed 08/20/2007

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