Free Application - District Court of Arizona - Arizona

David N. Ingrassia (#010936) DAVID N. INGRASSIA, P.C. 1212 East Osborn Road Phoenix, Arizona 85014 Telephone: (602) 604-0099 Facsimile: (602) 604-0110 Attorneys for Plaintiffs IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA CITICAPITAL TECHNOLOGY FINANCE, INC., formerly known as EAB Leasing Corp., a Pennsylvania corporation, and CITICAPITAL COMMERCIAL LEASING CORPORATION, formerly known as Associates Leasing, Inc., an Indiana corporation, predecessor in interest to real party in interest, GENERAL ELECTRIC CAPITAL CORPORATION, Plaintiffs, vs. GRANT H. GOODMAN AND TERI B. GOODMAN, husband and wife, Defendants.
CLEAR CHANNEL BROADCASTING, INC., Garnishee.

Case No. CV03-01587 PHX JAT

GENERAL ELECTRIC CAPITAL CORPORATION'S APPLICATION
FOR ORDER OF CONTINUING LIEN AGAINST GARNISHEE

COMES NOW the Plaintiff/Judgment Creditor, GENERAL ELECTRIC CAPITAL CORPORATION, by and through its undersigned counsel, pursuant to A.R.S. §12-1598.10 (A) and states as follows:

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1.

On or about April 10, 2007, a Writ of Garnishment of Earnings was

served on the Garnishee herein; 2. On or about May 18, 2007, the Garnishee filed its Answer with the

court stating that the Judgment Debtor, Teri B. Goodman, was employed by Garnishee on the date the Writ of Garnishment was served, that earnings were owed to said Judgment Debtor, and that Judgment Debtor was subject to an existing garnishment in favor of California Portland Cement Co.; 3. No timely, written objection has been filed herein to the Writ of

Garnishment or the Answer of Garnishee. WHEREFORE the Plaintiff respectfully applies to the Court for the entry of an Order directing Garnishee to pay over to Plaintiff as the Judgment Creditor all non-exempt earnings withheld from the wages of Judgment Debtor Teri B. Goodman under the Writ of Garnishment herein beginning with the pay period during which the Writ of Garnishment was served and continuing as a lien on the non-exempt earnings of said Judgment Debtor until further order of this Court. RESPECTFULLY SUBMITTED THIS 14th day of June, 2007.

DAVID N. INGRASSIA, P.C. /s/ David N. Ingrassia David N. Ingrassia 1212 E. Osborn Road Phoenix, AZ 85014 Attorney for Plaintiff/Judgment Creditor

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Copy of the foregoing mailed this 14th day of June, 2007 to: Teri B. Goodman 4156 N. 49th Street Phoenix, AZ 85018 Grant H. Goodman Grant H. Goodman, PLLC 4156 N. 49th Street Phoenix, AZ 85018 Grant H. Goodman Grant H. Goodman, PLLC 5110 N. 44th Street, Suite L-200 Phoenix, AZ 85018 Clear Channel Broadcasting, Inc. c/o Corporate Service Company, Statutory Agent 2338 W. Royal Palm Road, Suite J Phoenix, AZ 85021 Clear Channel Broadcasting, Inc. 20880 Stone Oak Parkway San Antonio, TX 78258 /s/ David N. Ingrassia

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