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 g
4 Michael Zdancewicz (#12426)
5 Michael@,mzp1lc.com
Attorneys for Judgment Creditor
6
UNIIED SIAIES DISIRIC1 COURI E
8 DISIRICI OF ARIZONA
9
LAWRENCE .J WARFIELD, as Receiver, Case No.: CV 03-2390-PHX-JAI
10
Judgment Creditor, APPLICATION FOR WRIT
U OF GARNISHMENT
vs. ‘
I2 (Earnings) p
13 MICHAEL ALANIZ; PAUL RICHARD; et al ,
It Judgment Debtor s,
is
RELIAS IAR LIFE INSURANCE CO., ?
16 1
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`Garnishment, stating the following:
20 1 Ihe 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 “Iudgrnent 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 of his wages until the Judgment is satisfied
3.. Judgment Debtor owes at least:
Judgment Amount as to Paul Richard
Principal: $64,*700 .00 I
Prejudgrnerrt interest: $23 ,139.00
1
Case 2:03-cv-02390-JAT Document 632 Filed 08/19/2007 Page 1 of 2 I

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 iiom February 28, 2007 until the date of the Writ (August 20, 2007) ($3.,08 per day
5 rate X 173 days) inthe amount of $532 .84
TOTAL AMOUNT DUE as of August 20, 2007 fbr which no payment has been
6 made is $112,23919.
7 4, That the Garnishee is believed to be an employer of the Judgment Debtor or
3 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
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.
14 THEREFORE, I request that a Writ of Garnishment be issued.
15 Dated this 2 day Or [@0/ S17 ,200}
16
1\/1ICHAEIQ?ANCEWICZ, P. .C.
17 ‘ ·
6/4 ar!
18 /s/ ichael Zdance #12426)
19 Michael Zdancewic
3550 North Central Avenue, Suite 710 _
20 Phoenix, Arizona 85012 `
21
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23 - §
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Case 2:03-cv-02390-JAT

Document 632

Filed 08/19/2007

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Case 2:03-cv-02390-JAT

Document 632

Filed 08/19/2007

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