Free Application for Writ - District Court of Arizona - Arizona

1 MICILAEL ZDANCEWICZ, P.L.L.,C. -
2 3550 North Central Avenue, Suite 710
Phoenix, Arizona 85012
3 Phone (602) 266-1327 p
Facsimile (602) 265-4391
4 Michael Zdancewicz (#12426)
5 Michael llc.com ‘
Attorneys for Judgment Creditor
6
UNITED STATES DISTRICT COURT
I
8 DISTRICT OF ARIZONA j
9
LAWRENCE I. WARFIELD, as Receiver, Case No.: CV 03-23 90-PI-lX- JAT
10 E
Judgment Creditor, APPLICATION F OR WRIT
U OF Gxtmrsmvrnnr ;
12 VS-~ _ 1
(Earnings) ,
13 MICHAEL ALANIZ; CHARLES DAVIS; et
14 al.,
15 Judgment Debtors,
16 ALLIANZ LIFE INSURANCE CO, OF
I 7 NORTH AMERICA,
jg Garnishee.
jg I am the attorney for the Judgment Creditor in this action and I make this application
20 for issuance ofa Writ ofGamisl1ment, stating the following:
21 1. The .Iudgment Creditor is a party in an action to whom a money judgment has
22 been awarded. I
23 2 The Judgment Creditor has made demand on Charles Davis (hereafter the
24 ",Iudgment Debtor") for the payment of the amount adjudged due, but the Judgment Debtor
25 has not paid that amount and Judgment Debtor has not agreed and continued to pay the non- i
exempt portion of his wages until the Judgment is satistied.
3. Judgment Debtor owes at least:
Case 2:03-cv-02390-JAT Document 660 Filed 08/19/2007 Page 1 of 2 i

I Judgment Amount as to Charles Davis
2 Principal: t $109,900 .00
Prejudgment interest: $39,305.00
3 Plus accruing interest on the unpaid principal at the Federal Judgment Rate of 5.05%
per annum from February 28, 2007 until the date ofthe Writ (August 20, 2007) ($15 .21 per
4 day rate X 173 days)in the amount of` $2,631..33
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
8 made is $174,65217.
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.
11 5. That Judgment Creditor has not received notice ofthe Judgment Debtor(s)
12 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 Judgment 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 rit of Garnishment be issued.
17 Dated this i 2 day of , 200/2 {
is i){?NCE CZ, P. .C
19 _ 2
/ eu! Q
20 /s/ Michael Zdancewic #12426)
Michael Zdancewicz
21 3550 North Central Avenue, Suite 710
22 Phoenix, Arizona 85012
24
25
2 .
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Case 2:03-cv-02390-JAT

Document 660

Filed 08/19/2007

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Case 2:03-cv-02390-JAT

Document 660

Filed 08/19/2007

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