Free Application for Writ - District Court of Arizona - Arizona

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FENNEMORE CRAIG , P.C.
P HOENIX

FENNEMORE CRAIG, P.C. Janet Weinstein (No. 011910) Kevin J. Bonner (No. 017944) Nicolas B. Hoskins (No. 023277) 3003 North Central Avenue Suite 2600 Phoenix, Arizona 85012-2913 Telephone: (602) 916-5000 Email: [email protected] Attorneys for Plaintiff

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA Century 21 Real Estate Corporation, Plaintiff, v. Daryush B. Motlagh and Jane Doe Motlagh, husband and wife; Integrity Assurance, Inc. an Arizona corporation, Defendants. Daryush B. Motlagh and Jennifer Motlagh, husband and wife; Integrity Assurance, Inc., an Arizona corporation, Counterclaimants, v. Century 21 Real Estate Corporation, a Delaware corporation doing business in the State of Arizona, Does(s) 1 through 100, Counterdefendants. Wells Fargo Bank, N.A., Garnishee. APPLICATION FOR WRIT GARNISHMENT (Non-Earnings) OF No. CIV 03 2353-PHX-DGC

(Assigned to the Hon. David G. Campbell)

Case 2:03-cv-02353-DGC

Document 104

Filed 06/22/2007

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FENNEMORE CRAIG , P.C.
P HOENIX

1. Century 21 Real Estate Corporation (the "Judgment Creditor") is the Judgment Creditor of Daryush B. Motlagh and Jennifer Motlagh (the "Judgment Debtor"). 2. The Judgment Creditor has good reason to believe that: (a) (b) (c) (d) The Garnishee is indebted to the Judgment Debtor for monies which are not earnings; or The Garnishee is holding non-exempt monies on behalf of the Judgment Debtor; or The Garnishee has in their possession non-exempt personal property belonging to the Judgment Debtor; or The Garnishee is a corporation, and the Judgment Debtors are the owners of shares in such corporation, or has a proprietary interest in the corporation.

3. The Judgment Creditor has been awarded a judgment against the Judgment Debtor dated March 20, 2007 in the amount of $52,721.00 in the United States District Court, District of Arizona. The total amount due on the Judgment as of June 22, 2007 is $53,390.28, reflecting principal of $52,721.00, and accrued post judgment interest of $669.28. Interest accrues on the Judgment at the rate of 4.93% per annum, which presently equals $7.12 per day. 4. The address of the Garnishee is as follows: Wells Fargo Bank, N.A. 3002 N. Central Ave. Phoenix, Arizona 85012 WHEREFORE, the Judgment Creditor asks that the Court issue a Writ of Garnishment of monies or property and a summons pursuant to A.R.S. § 12-1574. DATED this 22nd day of June, 2007. FENNEMORE CRAIG, P.C.

By/s/ Nicolas B. Hoskins Janet Weinstein Kevin J. Bonner Nicolas B. Hoskins Attorneys for Plaintiff Century 21 Real Estate Corporation

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FENNEMORE CRAIG , P.C.
P HOENIX

ORIGINAL of the foregoing Filed electronically this 22nd day of June, 2007, with: United States District Court District of Arizona 401 West Washington Street Phoenix, AZ 85003 /s/
1928552

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