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 [email protected]
Attorneys for Judgment Creditor
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UNITED STATES DISTRICT COURT
7 .
8 DISTRICT OP ARIZONA
9 s
LAWRENCE J. WARFIELD, as Receiver, Case No.: CV 0.3-2.390-PI-IX- JAT
10 Z
Judgment Creditor, APPLICATION FOR WRIT
H or GARNrsmvrnNr
12 VS. I ¤
(Earnings) I
I3 MICHAEL ALANIZ; PAUL RICHARD; et al.,
It Judgment Debtors,
is
PRESIDENTIAL LIFE INSURANCE CO.,
16 ?
17 Garnishee.
18 I am the attorney for the Judgment Creditor in this action and I make this application
19 for issuance ofa Writ of Gamishment, stating the following:
20 1. The Judgment Creditor is a party in an action to whom a money judgment has
2] been awarded. -
22 2. The Judgment Creditor has made demand on Paul Richard (hereafter the
23 "Judgment Debto1") 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 of his wages until the Judgment is satisfied.
3. Judgment Debtor owes at least: i
J udgment Amount as to Paul Richard .
Principal: $64,700..00 Q
Prejudgment interest: $23,139.00
I
Case 2:03-cv-02390-JAT Document 638 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 from 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 f`rom February 28, 2007 until the date of' the Writ (August 20, 2007) ($3.08 per day
5 rate x l73 days) in the amount off $532 84
TOTAL AMOUNT DUE as of August 20, 2007 for which no payment has been
6 made is $112,23919.
-7 4. That the Garnishee is believed to be an employer ofthe 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 constuner credit
U 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.
M THEREP ORE, T request that a Writ of Garnishment be issued.
15 Dated this f day of [ %gé , 2003. I
16 .
MTCHAE ZDANCEWICZ, P .C.
17 ,. 3
*8 rs! ranger Zdance ‘ #12426)
19 Michael Zdancewicz
3550 North Central Avenue, Suite 710
20 Phoenix, Arizona 85012 {
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Case 2:03-cv-02390-JAT

Document 638

Filed 08/19/2007

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Case 2:03-cv-02390-JAT

Document 638

Filed 08/19/2007

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