Free Answer to Writ of Garnishment - District Court of Arizona - Arizona

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1 FENNEMORE CRAIG, P.C. Y
Janet Weinstein (No. 011910) JUL 1 1 Zim Q
2 Kevin J. Bonner (No. 017944) CI HW H G W., . .,, J,. CO, BT 1
Nicolas B. Hoskins (No. 023277) " it {,,gi,{;t{;-§ ,,5.,- .;
3 3003 North Central Avenue . av, rrrr gg f'
Suite 2600 """‘“""`"”"` 7“``` `1
4 Phoenix, Arizona 85012-2913
Telephone: (602) 916-5000
5 Email; [email protected]
6 Attorneys for Plaintiff
7
8 UNITED STATES DISTRICT COURT
- 9 DISTRICT OF ARIZONA
10 Century 21 Real Estate Corporation,
11 Plaintiff, No. CIV 03 2353-PHX-DGC
12 v.
13 Daryush B. Motlagh and Jane Doe ANSWER TO GARNISHMENT
Motlagh, husband and wife; Integrity (N0n—Earnings)
14 Assurance, Inc. an Arizona corporation,
15 Defendants. (Assigned to the Hon. David G. Campbell)
16 Daryush B. Motlagh and Jennifer
Motlagh, husband and wife; Integrity
17 Assurance, Inc., an Arizona
corporation,
18
. Counterclaimants,
19
1 20 v'
Century 21 Real Estate Corgoration, a
21 Delaware corporation doin usiness in
the State of Arizona, Doesgs) 1 through
22 100,
23 Counterdefendants.
24 Wells Fargo Bank, N.A.,
25 Garnishee.
26
Fawuamoka CR.¤.1 Case 2:03—cv—02353-DGC Document 107 Filed 07/11/2007 Page 1 of 4

I I. I am the above named Garnishee or am authorized by the Gamishee to make this
affidavit on his behalf regarding the Writ of Garnishment served on Gamishee on
2 this date:
2 Ze 3 2
4 II. Was the Garnishee indebted to or otherwise in possession of monies ofthe Judgment
Debtors at the time the Writ was served?
5 Account Closed
[ ] Yes W No
6
III. What is the total amount of indebtedness or monies of the Judgment Debtors in the
7 possession ofthe Garnishee at the time the Writ was served? $ .
8 IV. What is the total amount of indebtedness or monies of the Judgment Debtors withheld
by the Garnishee pursuant to the Writ? $ .
9
V. \Vhat is the amount of indebtedness or monies of the Judgment Debtors not withheld
I0 by the Garnishee, and the reason for not withholding?
1 1 a. Amount of Indebtedness not Withheld: $ ;
I2 b. Reason for not Withholding:
13
I4
I5 VI. At the time the Writ of Garnishment was served upon Gamishee, did
Garnishee have possession of personal property of the Judgment Debtors?
I6
[ ] Yes 960
17
If yes, describe each item, or group of items, of personal property:
18
19
20 -
21 VII. Igilease list all items of personal property withheld by the Garnishee pursuant to the
ritz
22
23
24
25 VIII. Based upon Gamishee's knowledge, is another person or entity indebted to the
I Judgment Debtors, or in possession of personal property of the Judgment Debtors?
26
FEN'N'EM;)}:1;(5tt;alG.P.C W 1 -
i Case 2:03—cv—02353-DGC Document 107 Filed 07/11/2007 Page 2 of 4

1 [1 Yes W4)
2 If yes, give names and addresses:
3
4
5 . .
IX. If Gamishee is a corporation, do Judgment Debtors have now, or at the t1me the Writ
6 was served, any stocks, bonds, options or other interest in the Corporation?
7 []Yes []Nog_ __ g_
8 If yes, state the NUMBER AND TYPE of shares owned by the Judgment Debtors,
and a DESCRIPTION of any other interest the Judgment Debtors own in the
9 Garnishee Corporation as of the date the Writ was served, as shown on the
Corporations records:
10
ll
12
13 X. Did Garnishee answer "YES" to either question #2 or #6‘?
14 [ ] Yes wave
I5 If yes, copies of the Writ and Summons, underlyinjg Judgment, Notice to Judgment
Debtors, and Request for Hearing were delivered to udgment Debtors on:
I6
17 `—”__`1’
BY: [] hand delivery;
18 ·
[] regular first class mail to the address determined to be the best
l9 ca culated to reach the Judgment Debtors in a timely manner;
20 [] service pursuant to the Rules of Civil Procedure applicable to a
Summons.
21 - e
XI. Copies of this Answer were delivered on: [M. 0 9 W to the Judgment
22 De tors, the Judgment Creditor, or Judgment Cred1tor‘s attorney, it applicable, at the
following addresses:
23 _
24
25
BY: [] hand delivery;
26
FEmEmA|p;EFij;¤;a1o.P.C - 2 -
Case 2:03—cv—02353-DGC Document 107 Filed 07/11/2007 Page 3 of 4

I 2( regular first class mail to the address determined to be the best
‘ ca culated to reach the Judgment Debtors in a timely manner;
2
[ ] service pursuant to the Rules of Civil Procedure applicable t0 a
3 Summons.
4 . .
XII. Garnishee’s name, marling address and telephone number 1s:
5
6
WELLS FARGO BANK
7 LEVY PROCESSING
MAC 83928-021 A A A · A· ··
8 PO BOX 29779 ‘
PHOENIX, AZ 85038-9779 480-724-2120
g .
10
ll XIII. I have read the foregoing document and know of my own knowledge that the facts
stated therein are true an correct.
12
WHEREFORE, Gamishee prays that Garnishee be discharged on this Answer and
I3 that the Court award Garnishee reasonable compensation in the amount of $ .
I4
15 STATE OF ARIZONA )
) ss.
16 County of Maricopa )
17 '
18 gn tur o amishee or
Authorized Agent
19
F
20 SUBSCRIBED AND SWORN this date: ‘u’ 0 9 Zm? .
21 '_ p_._. ,..
22 H — ·
tary Public
23
24 My commission expires:
25 , . .. E
wzssue JUL · ' AL
26 N0T""“'Pl§Lr?£§?PE?
H1', My C MARICOPA C5§N0;$”2UN3
FENNEMORE Cvmcr PC - 3 _ Umm. EXPITES JUNE 3. 20m
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