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



he used in another case.

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