Free Motion for Judgment Debtor Exam - District Court of Arizona - Arizona

1 Gordon S. Bueler
Bueler Jones LLP
2 1300 North McClintock Drive, Suite B-4
3 Chandler, AZ 85226
(480) 775-6400 Fax (480) 775-8868
4 STATE BARNO. 011415 _
5 Attorneys for Plaintiffs
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7 IN THE UNITED STATES DISTRICT COURT
8 FOR THE DISTRICT OF ARIZONA
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10 RONALD H. WALECKI et ux., ) Case No.:CIV 02-2037 PHX SRB
1 1 _ )
Plaintiffs, {
12 vs_ ) MOTION FOR SUPPLEMENTAL
13 ) PROCEEDINGS - JUDGMENT
1=oRNEY ENrE1u>R1sEs, mc., etal., ) DEBTOR’S EXAMINATION
14 ) .
Defendants. )
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)
16 A
17 The Judgment Creditor, Ronald H. Walecki, by and through his attorney, hereby moves for
18 an order requiring Doylan Forney, Judgment Debtor, to appear and answer questions under oath
19 concerning property of the Judgment Debtor and ordering Judgment Debtor to bring such records
20 and doctunents as may be required, and as listed in Exhibit A to this motion.
I 21 The affidavit of Ronald H. Walecki is attached to this motion. I
22 Respectfully submitted this 20 day of August 2005.
23 Bueler Jones LLP 2
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25 Gordon S. Bueler
Attorney for Petitioner
ase 2:02—cv—02037-SRB Document 42-2 Filed 09/01 /2005 Page 1 of 4

1 Ori inal tiled and copy hand-delivered
2 this@day of August 2005, with:
Clerk of the Court
3 401 West Washington Street
. 4 Phoenix, Arizona 85003
5 &I'1d
5 Honorable Susan Bolton
U.S. District Judge
7 401 West Washington Street, SPC 12
Phoenix, Arizona 85003
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Copy mailed this i&day of
9 August 2005, to:
10 Robert Blesch
11 3131 East Camelback Road, Suite 200
Phoenix, Arizona 85016-4599
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ase 2:O2—cv—O2037-SRB Document 42-2 Filed O9/O1/2005 Page 2 of 4

1 AFFIDAVIT
2 UNITED STATES DISTRICT COURT )-
) ss.
3 District of Arizona )
4 Ronald H. Walecki deposes and says:
5 1. I am the judgment creditor and, as such, am authorized to make this atidavit.
6 2. On»July 27, 2004, United..Statcs District Court, in the District of Arizona gave the
7 judgment against the judgment debtor Dey1aneFerney·in the am0unte»ofl$306,667;55.
8 3. I believe that Doylan Forney is aijudgment debtor and has infomation or documents
9 in his possession that states Judgment Debtor’s assets.
10 DATED this Qt; day ur August 2005
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Ronald H. Walecki
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15 SUB L , 4- B ji! AND SWORN to before me this date: Ct} [1/9`[ jb; gym?
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ase 2:O2—cv—O2037-SRB Document 42-2 Filed O9/O1/2005 Page 3 of 4

1 EXHIBIT ‘A’
2 List of documents to be produced at supplemental proceedings by the Judgment Debtors.
3 l. Federal and state income tax returns for the two years proceeding the date of this order,
4 any quarterly estimates of federal or state income tax filed by you for this year.
5 2. Bank statements on checking and savings accounts from any bank, savings and loan
associations or shared accounts in any credit union belonging to you or in which you have or
6 have had any interest whatsoever, alone or jointly, with any other person or persons.
7 3. Certificates of any stocks and bonds, including any stock certificates or other evidence of
ownership of stock of V & J Foods, belonging to you or in which you have or have had any
8 interest, whatsoever, either alone or jointly with any other person or persons.
9 4. Life insurance policies upon your life or naming you as a beneficiary.
10 5. Notes, contracts, negotiable instruments receivable or accounts receivable, whether due
11 or not, belonging to you or in which you have or have had any interest whatsoever.
12 6. Real property: titles, deeds or contracts of sale of property owned, purchased or being
purchased, or sold, which you own or have had any interest in whatsoever, either alone or jointly
13 with any other person or persons.
14 7. Personal property: titles, bills of sale or contracts of sale upon, including, but not limited
to, automobiles, boats, household goods, furniture and fixtures belonging to you or in which you
15 have or have had any interest, whatsoever, either alone or jointly with any other person or
persons. .
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ase 2:O2—cv—O2037-SBB Document 42-2 Filed O9/O1/2005 Page 4 of 4

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