Free Application for Writ - District Court of Arizona - Arizona

1 Elizabeth A. Petersen (#018377)
Robert G. Vaught (#020717)
2 SNELL & WILMER L.L.P.
One Arizona Center
3 400 East Van Buren
Phoenix, AZ 85004-2202
4 602-382-6378
Attorneys for Defendants
5 DriveTime Corporation and Ernie Garcia
6
IN THE UNITED STATES DISTRICT COURT
7
FOR THE DISTRICT OF ARIZONA
8
9 Janet Rose Roth, ( No. CV-03-0839-PHX-SRB
10 Plaintiff/Judgment Debtor, APPLICATION FOR WRIT OF
GARNISHMENT OF EARNINGS
$1 H V- . . .
E ` SE 12 Dr1veT1me Corporation and Ernie
§ I _ Garcia CEO et al (Ugly Duckling),
5=“=`§§§ 13
$8 “ Defendants/Judgment Creditors,
W Qi 15 US Airways, Inc., a Delaware
O corporation
16
Garnishee.
17
18 1. The undersigned is the attorney for the above-named Defendants/Judgment
19 Creditors, DriveTime Corporation and Ernie Garcia CEO et al (Ugly Duckling),
20 (hereinafter "judgment creditors"). The judgment creditors are parties in this action to
21 whom a money judgment has been awarded.
22 2. Judgment creditors have made demand on the judgment debtor Janet Rose
23 Roth, for payment of the amount adjudged due, but the judgment debtor has not paid that
24 amount and has not agreed to pay the nonexempt portion of her wages until the judgment
25 is satisfied. The outstanding balance due on the Judgment against Janet Rose Roth, as of
26 this date is for the principal amount of $47,322.60 plus accrued and accruing interest
1774264.1
ase 2:03-cv-00839-SRB Document 187 Filed O1/06/2006 Paget of2

1 thereon at the rate of 10% per annum from July 15, 2005 until paid in full.
2 3. Gamishee, US Airways, is believed to be an employer of the plaintiff/
3 judgment debtor Janet Rose Roth or otherwise owes or will owe to the Judgment
4 disposable earnings.
5 4. The address for Garnishee or his authorized agent is:
6 US Airways
7 c/o C T Corporation System, Statutory Agent
3225 North Central Avenue
8 Phoenix, Arizona 85012
9 5. The judgment creditors have not received notice of judgment debtor, Janet
10 Rose Roth's intent to enter into an agreement for debt scheduling with a qualified
E 11 consumer credit counseling service, or, if such notice has been received, that judgment
E i 12 creditors have timely objected to judgment debtor's participation.
13 Te
_ I 14 RESPECTFULLY SUBMITTED this day of January, 2006.
un
5, 15 SNELL & WILMER L.L.P.
O 7 J
I6 Q . .__,__
Elizab”e h A. Petersen
jg Robe G. Vaught
On rizona Center
jg 400 ast Van Buren
Phoenix, AZ 85004-2202 _
20 Attorneys for Defendants D1iveTime Corporation
and Ernie Garcia
21
22 `
23
24
25
26
1774264.1 2
ase 2:03-cv-00839-SBB Document 187` _FiIed O1/06/2006 Page 2 of 2

Case 2:03-cv-00839-SRB

Document 187

Filed 01/06/2006

Page 1 of 2

Case 2:03-cv-00839-SRB

Document 187

Filed 01/06/2006

Page 2 of 2