1 MICHAEL ZDANCEWICZ, P.L .L C.
2 3550 North Central Avenue, Suite 710
Phoenix, Arizona 85012 j
3 Phone (602) 266·1327 Q
Facsimile (602) 265-4391
4 Michael Zdancevvicz (#12426)
5 Michael@m;_pllc.com
Attorneys for Judgment Creditor
6 J
UNITED STATES DISTRICT COURT j
7 T
8 DISTRICT OF ARIZONA
LAWRENCE J WARFIELD, as Receiver, Case No.: CV 03-2390-PHX—JAT I
10 {
Judgment Creditor, APPLICATION FOR WRIT P
1* or GARNISHMENT g
vs. `
12 (Earnirrgs) ,
13 MICHAEL ALANIZ; CHARLES DAVIS; et $
14 al.,
15 Judgment Debtors,
16 AMERICAN EQUITY INVESTMENT LIFE
17 INSURANCE CO.,
18 Garnishee. P
19 I am the attorney for the Judgment Creditor in this action and I make this application
20 for issuance of' a Writ of Garnishment, stating the following:
21 1.. 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 “Iudgment Debtorâ€) for the payment ofthe amount adjudged due, but the Judgment Debtor A
25 has not paid that arnotmt and Judgment Debtor has not agreed and continued to pay the non-
exempt portion ofhis wages until the Judgment is satisfied. Q
3. Judgment Debtor owes at least:
1
Case 2:03-cv-02390-JAT Document 650 Filed 08/19/2007 Page 1 of 2
1 J udgment 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 Judgment 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
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 ofthe 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 $174,652.11
9 4. That the Garnishee is believed to be an employer ofthe Judgment Debtor or
10 otherwise owes or will owe to the Judgment Debtor disposable earnings.
H 5. That Judgment Creditor has not received notice of the Judgment Debtor(s)
12 intent to enter into an agreement f`or debt scheduling with a qualified consurner credit
rg, counseling service or, if` such notice has been received, that he timely objected in writing, to
14 the Judgment Debtor s partici ation in such an agreement or that he has been notified that the
P
15 agreement is no longer effective-
16 TI-IEREP ORE, T request that a rit of Garnishment be issued.
17 Dated this [ day of 057L ,200} `
18 Mrourrn zo cn cz ....
19 q
{L
20 /s/ Michael Zdan ` #12426)
Michael Zdance `cz
21 3550 North Centra A e, Suite 710
22 Phoenix, Arizona 85012
23
24
25
2 E
Case 2:03-cv-02390-JAT Document 650 Filed 08/19/2007 Page 2 of 2
Case 2:03-cv-02390-JAT
Document 650
Filed 08/19/2007
Page 1 of 2
Case 2:03-cv-02390-JAT
Document 650
Filed 08/19/2007
Page 2 of 2