Free Application for Writ - District Court of Arizona - Arizona

1 MICHAEL ZDANCEWICZ, P.L.L.C. I
2 3550 North Central Avenue, Suite 710
Phoenix, Arizona 85012
3 Phone (602) 266-1327
Facsimile (602) 265-4391
4 Michael Zdancewicz (#12426)
5 Michael@,mzpllc.com "
Attorneys for Judgment Creditor
6
UNITED STATES DISTRICT COURT
7
8 DISTRICT OF ARIZONA
9 .
LAWRENCE J. WARF IELD, as Receiver, Case No .: CV 03-2390-PHX-JAT g
I0 ;
Judgment Creditor, APPLICATION FOR WRIT
II on GARNISHMENT
12 VS1- _
(Earnings) ¢
13 MICHAEL ALANIZ; PAUL RICHARD; et al , T
It Judgment Debtors,
I5
AMERUS LIFE INSURANCE CO.,
I6
17 Garnishee.
18 I am the attorney for the Judgment Creditor in this action and I make this application
19 for issuance ofa Writ ofGarnishment, stating the following: _
20 I. The Judgment Creditor is a party in an action to whom a money judgment has
gl been awarded.
22 2. The Judgment Creditor has made demand on Paul Richard (hereafter the
23 "Judgment Debtor") for the payment ofthe amount adjudged due, but the Judgment Debtor
24 has not paid that amount and Judgment Debtor has not agreed and continued to pay the non-
25 exempt portion ot his wages Lmtil the Judgment is satisfied.
3 Judgment Debtor owes at least:
Judgment Amount as to Paul Richard
Principal: $64,700.,00
Prejudgment interest: $23,139 .00
I Q
Case 2:03-cv-02390-JAT Document 649 Filed 08/19/2007 Page 1 of 2

I Plus accruing interest on the unpaid principal at the Federal Judgment Rate of 5 05%
2 per annum horn February 28, 2007 until the date ofthe Writ (August 20, 2007) ($8 95 per day
rate x 173 days)in the amount of $1,584.35
3 Taxable Costs: $22,283.00
Plus accruing interest on Taxable Costs at the Federal Judgment Rate of 5.05% per
4 annum from February 28, 2007 until the date ofthe Writ (August 20, 2007) ($3..08 per day
5 rate x l73 days) in the amount of $532..84
TOTAL AMOUNT DUE as of August 20, 2007 for which no payment has been
6 made is $112,239..19.
7 4. That the Garnishee is believed to be an employer of the Judgment Debtor or
g otherwise owes or will owe to the Judgment Debtor disposable earnings.
9 5. That Judgment Creditor has not received notice of the Judgment Debtor’s
10 intent to enter into an agreement for debt scheduling with a qualified consumer credit
ll counseling service or, if such notice has been received, that he timely objected in writing, to
12 the Judgment Debtor’s participation in such an agreement or that he has been notified that the
13 agreement is no longer effective.
14 THEREFORE, I request that a Writ of Garnishment be issued.
15 Dated this / day of [;7l[§0§7L , 2003
16
MICHAEL ZDANCE TCZ, .
T7"}/JJ
lg /s/ Michael Zdancew #l2426) 2
19 Michael Zdancewicz ;
3550 North Central Avenue, Suite 710
20 Phoenix, Arizona 850l2
21 i
22 3
23
25
Y
Case 2:03-cv-02390-JAT Document 649 Filed 08/19/2007 Page 2 of 2

Case 2:03-cv-02390-JAT

Document 649

Filed 08/19/2007

Page 1 of 2

Case 2:03-cv-02390-JAT

Document 649

Filed 08/19/2007

Page 2 of 2