prepare a motion for garnishment

Once a judgment is obtained (through either a default judgment, court order, or jury verdict), then what? The prevailing party must enforce the judgment. In this case, you are a paralegal working for Mr. Dewey Cheatham, Esq., a partner at Cheatham & Fare, One First St, Greenacre, in your home state.

The firm has a client, Silence DoGood, who has filed a complaint for negligence stemming from an auto accident, against Nick Slick. The complaint was filed around September 1, 2015. In the complaint, Ms. DoGood requested $50,000 in damages for emotional distress, anxiety, and compensation, after Nick Slick negligently damaged a box of letters Ms. DoGood had been keeping. He was supposed to restore the letters, which were family heirlooms, but ended up burning the letters beyond repair.

The case has been pending in Greenacre district court. The Greenacre court issued a summons on September 3, 2015, by certified mail. It was returned having been claimed on October 1, 2015. No answer or other document has been filed by Nick Slick.

Mr. Cheatham filed a Motion for Default Judgment, which was granted by the court. After a damages hearing occurred, the court issued judgment in favor of Ms. DoGood in the amount of $35,673. Mr. Cheatham has asked you to prepare a motion for garnishment, along with any other documents needed to obtain the funds from Mr. Slick’s bank account with Greenacre Mutual Bank. He has provided you with a sample motion and affidavit he used in another case.

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