I MICHAEL ZDANCEWICZ, P .L.L C.
2 3550 North Central Avenue, Suite 710
Phoenix, Arizona 85012 p
3 Phone (602) 266-1327 {
Facsimile (602) 265-4391
4 Michael Zdancewicz (#12426) 2
5 [email protected]
Attorneys for Judgment Creditor
5
UNITED STATES DISTRICT COURT I
7
8 DISTRICT OF ARIZONA
9 I
LAWRENCE J. WARFIELD, as Receiver, Case No.: CV 03-2390-PHX-JAT j
10 _
Judgment Creditor, APPLICATION FOR WRIT
U or GARNISHMENT
vs.
12 (Earnings)
13 MICHAEL ALANIZ; CHARLES DAVIS; et
14 BL A
15 Judgment Debtors,
16 OM FINANCIAL LIFE INSURANCE CO.,
U 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:
20
1.. The Judgment Creditor is a party in an action to whom a money judgment has
21
been awarded. f
22 ‘
2. The Judgment Creditor has made demand on Charles J. Davis (hereafter the 1
24 “Judgrnent Debtor") for the payment ofthe 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-
exempt portion ofhis wages until the Judgment is satisfied. I
3. Judgment Debtor owes at least: Q
J udgment Amounts as to Charles Davis Q
Principal: ` $109,900 .00 E
-
Case 2:03-cv-02390-JAT Document 655 Filed 08/19/2007 Page 1 of 2 .
1 Prejudgment interest: $3 9,305 .00
2 Plus accruing interest on the unpaid principal at the Federal .Judgment Rate of 5 .05%
per annum f`rom February 28, 2007 until the date ofthe Writ (August 20, 2007) ($15.21 per
3 day rate x 173 days)in the amount of $2,631.33
Taxable Costs: $22,283 .00
4 Plus accruing interest on Taxable Costs at the Federal Judgment Rate of 5.05% per
5 annum Hom 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
6 TOTAL AMOUNT DUE as of August 20, 2007 for which no payment has been
made is $174,652.17.
7
4.. That the Garnishee is believed to be an employer of the Judgment Debtor or
8
otherwise owes or will owe to the Judgment Debtor disposable earnings.
9
5. That Judgment Creditor has not received notice of the Judgment Debt0r’s
l0
ll 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
13 the .Judgment Debtorâ€s 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 Oi day of gl , 200L?
17 MICHAEL ZDANCEWICZ, C.
18 Q7?]
19 /s/ Michael Zdancew` #12426)
Michael Zdancewicz _
20 3550 North Central Avenue, Suite 710 J
21 Phoenix, Arizona 850l2
22
23
24
25
-
Case 2:03-cv-02390-JAT Document 655 Filed 08/19/2007 Page 2 of 2 5
Case 2:03-cv-02390-JAT
Document 655
Filed 08/19/2007
Page 1 of 2
Case 2:03-cv-02390-JAT
Document 655
Filed 08/19/2007
Page 2 of 2