Once a judgment is obtained (through either a default judgment, court order, or jury verdict), then what? In your ungraded activity this week, you prepared a motion for garnishment. Mr. Dewey Cheatham, Esq., would like a memorandum explaining all the options to enforce the judgment in this case and ways in which the Defendant might try to evade the enforcement of the judgment. At a minimum, you should discuss three (3) ways Mr. Cheatham can seek to enforce the judgment and three (3) ways in which Defendant might attempt to evade enforcement.

As a reminder, the following are the facts of the case:

Silence DoGood, who has filed a complaint for negligence stemming from an auto accident against Nick Slick. The complaint was completed on September 1, 2015. In the complaint, Ms. 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 via certified mail on September 3, 2015; it was returned after being claimed on October 1, 2015. Nick Slick has filed no answer or other document. Mr. Cheatham filed a Motion for Default Judgment, which the court granted. After a damages hearing, the court issued a judgment in favor of the Courts of $35,673.

Your assignment should be formatted as a memorandum from your supervising attorney to the client. with proper formatting, spelling, and grammar. You should use at least three (3) primary legal sources formatted according to Bluebook Standards. For writing assistance, consider using Grammarly or submitting your written assignment to the Writing Lab before submitting it.

• Your memo should contain the following sections:
• Heading or Caption
• Facts
• Issue(s) Presented
• Answer to Issue
• Reasoning or Discussion
• Conclusion

THIS IS THE MOTION TO GARNISH

IN THE DISTRICT COURT OF WANDERLUST****************************************************************************SILENCE DOGOOD, Plaintiff v.NICK SLICK, Defendant)))))))))Case No. 25-1520Judge Dillon WigleMOTION FOR DEFAULT JUDGMENTDewey Cheatham, Esq.Cheatham & Fare One First StGreenacre, Florida(325)367-3949Attorney for Plaintiff***************************************************************************PLAINTIFF'S MOTION FOR DEFAULT JUDGMENTNow comes the Plaintiff, Silence DoGood, by and through the undersigned Counsel, and respectfully moves this Honorable Court, under Civil Rule 55, for a judgment by default against the Defendant, Nick Slick. This motion is made because the Defendant has failed to respond or defend himself in this action, despite proper notice, and offers the following facts and arguments in support:

On or about September 1, 2015, Plaintiff filed a Complaint in this Court against Defendant for negligence resulting from the willful destruction of personal property. In the ComplaintPlaintiff soughtht a judgment against Defendant Nick Slick for $50,000, which encompasses claims for emotional distress, anxiety, and damages arising from the negligent mishandling of a box of letters that hold significant sentimental value as family heirlooms. These irreplaceable and cherished letters were entrusted to the Defendant for restoration. However, in a shocking turn of events, Defendant failed to preserve the letters, ultimately resulting in their destruction through incinerationrendering them beyond repair and recovery. In addition to the monetary damages, Plaintiff further requests the Court to award costs associated with this legal action, interest on the judgment at the highest rate permissible under the law, and reasonable attorney fees incurred due to pursuing redress for these damages . The Greenacre District Court took the appropriate steps to ensure the Defendant was informed of this action by issuing a summons and a certified copy of the Complaint, which was compliant to the Defendant via certified mail on September 3, 2015. The postal service records indicate that Defendant claimed this accredited mail on October 1, 2015, confirming that he was made aware of the claims brought against him. Despite being duly notified, Defendant Nick Slick has not filed an Answer, has not appeared before the Court, and has failed to take Courtction to defend himself in the matter at hand. His silence and failure to respond reflect a blatant disregard for the legal process and an abandonment of his responsibilities from the allegations against him.

Wherefore, based upon the above facts and Defendant's lack of responsive action, Plaintiff respectfully requests that this Court enter a defaultjudgment ont Defendant Nick Slick, as outlined in Civil Rule 55. Respectfully submitted, /s/ Dewey Cheatham _________________________ Cheatham & Fare One First St Greenacre, Florida (325)367-3949 Attorney for PlaintiffCERTIFICATE OF SERVICE II certify that a true and accurate copy of the Motion for Default Judgment was sent through ordinary U.S. Mail on this 23rd day of December,2015. The do ument was addressed to Nick Slick at [Insert Address], who is the Defendant in this matter.____________________________________

IN THE DISTRICT COURTWANDERLUST: This matter came before the Court of the Plaintiff's Motion for Default Judgment, which was filed in connection with the case addressing negligence claims. After thoroughly reviewing the Motion and the supporting record, the Court makes the following findCourt1. The Plaintiff, Silence DoGood, initiated legal proceedings by filing a Complaint against the Defendant, Nick Slick, on September 1, 2015, alleging negligence that resulted in insignificant harm.2. The Defendant was properly served with the legal Complaint on October 1, 2015.Despite this service, Defendant has failed to respond by filing an Answer, appearing in court, or otherwise taking any Court to defend against the claims asserted by Plaintiff. Considering the above findings, the Court curry is now is issuingCurry the following order: IT IS now ORDERED that the Plaintiff's Motion for Default Judgment is GRANTED.Consequently, judgment is entered in favor of the Plaintiff, Silence DoGood, and against the SILENCE DOGOODPlaintiff, Vs.NICK SLICKDefendant. ))))))))Case No. 25-1520Judge Dillon WigleDEFAULT JUDGMENT ENTRY**************************************************************************

Defendant Nick Slick, in the total amount of $50,000. This sum is explicitly awarded fordamages related to emotional distress, anxiety, and compensation for the destruction of thePlaintiff's property caused by Defendant's negligent actions. Additionally, the Plaintiff is awarded the following: Legal costs incurred in bringing this action. Interest on the judgment amount at the highest rate permitted by law. Reasonable attorney fees for the legal services rendered in pursuit of this case.Furthermore, the Court sets a hearing to determine additional damages and to finalize the judgment. This hearing is scheduled for the 23rd day of December 2015, at 9 am, in Courtroom 5 of this Court.SO, ORDERED.____________Court________________ __________________________________12/01/2015 Judge Dillon Wigle