Free Application for Writ - District Court of Arizona - Arizona

I MICHAEL ZDANCEVVICZ, P L.IL.C.I
3550 North Central Avenue, Suite 710
2 Phoenix, Arizona 85012
3 Phone (602) 266-1327
F acsimile (602) 265—4391
4 Michael Zdancewicz (#12426)
5 Michae1@,mzpllc.com
Attorneys for Judgment Creditor
Y
UNITED STATES DISTRICT COURT
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8 DISTRICT OF ARIZONA
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LAWRENCE J. WARF IELD, as Receiver, Case No.; CV 03-2390-PHX—JAT ·
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Judgment Creditor, APPLICATION FOR WRIT
ll OF GARNISHMENT
12 VSII _
(Earmngs) _
I3 MICHAEL ALANIZ; CHARLES DAVIS; et E
al I, j
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15 Judgment Debtors,
I6 LAFAYETTE LIFE INSURANCE COI,
17 Garnishee.
18 I am the attorney for the Judgment Creditor in this action and I make this application
19 for issuance of'a Writ of Garnishment, stating the following:
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1 I The Judgment Creditor is a party in an action to whom a money judgment has }
21 {
been awarded A
22 I
2 The .Judgment Creditor has made demand on Charles J I Davis (hereafter the
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24 “Judgment 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-
exempt portion of his wages until the Judgment is satisfied.
3.I Judgment Debtor owes at least:
Judgent Amotmts as to Charles Davis
Principal: $109,900.00 T
Case 2:03-cv-02390-JAT Document 651 Filed 08/19/2007 Page 1 of 2

1 Prejudgment interest: $39,305 .00
2 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
3 day rate x 17.3 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 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 $174,652.17
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4. That the Garnishee is believed to be an employer ofthe Judgment Debtor or
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otherwise owes or will owe to the Judgment Debtor disposable earnings.
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5.. That Judgment Creditor has not received notice of the 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
13 the ludgrnent Debtor·’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. I
16 Dated this / day of [ Z , 200L%
17 MICHAEL ZD NC WICZ .C.
is my
19 /s/ Michael Zdance ` #12426) _
Michael Zdancewicz
20 3550 North Central Ave , Suite 710
21 Phoenix, Arizona 85012 ,
22
24
25 I I
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Case 2:03-cv-02390-JAT

Document 651

Filed 08/19/2007

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Case 2:03-cv-02390-JAT

Document 651

Filed 08/19/2007

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