Free Application for Writ - District Court of Arizona - Arizona

1 MICHAEL ZDANCEWICZ, P.L.L.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
6
UNITED STATES DISTRICT COURT
7
8 DISTRICT OP ARIZONA
9
LAWRENCE J., WARFIELD, as Receiver, Case No.: CV 03-2390-PHX-JAT
10
Judgment Creditor, APPLICATION FOR WRIT ‘
11 or GARNISHMENT
12 VS-I E
(Earnings)
13 MICHAEL ALANIZ; CHARLES DAVIS; et
14 al,
15 Judgment Debtors,
16 MIDLAND NATIONAL LIFE INSURANCE
CO-1,
I7 t
18 Garnishee.
19 I am the attorney for the Judgment Creditor in this action and I make this application
20 for issuance ofa Writ of` Garnishment, stating the following:
21 l. The Judgment Creditor is a party in an action to whom a money judgment has
22 been awarded.
23 2. The Judgment Creditor has made demand on Charles Davis (hereafter the
24 “Judgment Debto1") for the payment ofthe amount adjudged due, but the .Iudgment 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 satisiied, T
3. Judgment Debtor owes at least:
1 §
Case 2:03-cv-02390-JAT Document 654 Filed 08/19/2007 Page 1 of 2

I Judgent Amounts as to Charles Davis
2 Principal: $109,900,00
Prejudgment interest: $39,305 00
3 Plus accruing interest on the unpaid principal at the Federal iudgment Rate of 5 05%
per annum from February 28, 2007 until the date of` the Writ (August 20, 2007) ($15.21 per
4 day rate x 173 days)in the amount of $2,631..33
Taxable Costs: $22,283.00
5 Plus accruing interest on Taxable Costs at the Federal ludgment Rate of 5.05% per
6 annum from February 28, 2007 until the date ofthe Writ (August 20, 200'7) ($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 $174,652.11
9 4.. That the Garnishee is believed to be an employer ofthe Iudgment Debtor or
10 otherwise owes or will owe to the Judgment Debtor disposable earnings.
ll 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 I
14 the ludgrnent Debtor(s) participation in such an agreement or that he has been notified that the 1
15 agreement is no longer effective.
I6 THEREFORE, I request that a Writ of Garnishment be issued.
17 Dated this / day of {@2QC/S`lL , 2003
18 MICHAEL znrrucewrcz, r> .L.L.C.
I
19 W /4/my i
20 /s/ Michael Zdance 1 z #12426 j
Michael Zdancewi
21 3550 North Central enue, Suite 710
22 Phoenix, Arizona 85012
24
25 `
2
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Case 2:03-cv-02390-JAT

Document 654

Filed 08/19/2007

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Case 2:03-cv-02390-JAT

Document 654

Filed 08/19/2007

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