HONORABLE JOAN H. LEFKOW, MAGISTRATE JUDGE TO THE HONORABVLE NAN R. NOLAN ANSWER OF SPONGE CUSHION, INC. TO WRIT OF GARNISHMENT
Comes Now, Garnishee, Sponge Cushion, Inc., and makes this, its Answer to the Writ of Garnishment in the above styled action dated August 8, 2012:
1. For answer to paragraph 1 of the Writ of Garnishment, Sponge Cushion, Inc. states: Yes, per invoices on open account at the time of purported service of the Writ of Garnishment, $163,796.53 and during the intervening time and at the time of making of this Answer the $163,796.53 balance has increased to $206,861.21.
2. For answer to paragraph 2 of the Writ of Garnishment, Sponge Cushion, Inc. states: No, unless Garnishee chooses to make future product purchases from Judgment Debtor.
3. For answer to paragraph 3 of the Writ of Garnishment, Sponge Cushion, Inc. states: No.
4. For answer to paragraph 4 of the Writ of Garnishment, Sponge Cushion, Inc. states: No. 10573126v.1 7022/243868
Sponge Cushion, Inc. states that the Writ of Garnishment states that Sponge Cushion, Inc. has 30 days in which to answer. However, the Order on Motion For Writ of Garnishment as to Sponge Cushion entered 08/02/2012 contains what appears to be a clerical error in Paragraph 4 purporting to shorten the time to 20 days, and in a garbled passage, purporting to require the answer to the writ to consist, not of an answer to the writ, but of production of documents requested by a "Documents Dubpoena" (sic). To the extent that any response to the "Dubpeona" (Subpoena?) is required, Garnishee states that it served objections to the Subpoena upon Judgment Creditor's counsel and Judgment Debtor's counsel, and in response Judgment Creditor's counsel has verbally promised to reduce the scope of the subpoena requests and to agree to a protective order for any documents produced.
ATTORNEYS FOR SPONGE CUSHION, INC.
By:___/s/ Karen M. Rheingans_______________
Karen M. Rheingans, #6270492
Hawkins Parnell Thackston & Young, LLP. 10 S. Broadway, Suite 1300 St. Louis, MO 63102 314.678.8600 314.678.8686 firstname.lastname@example.org
The undersigned hereby certifies that a copy of the Answer to the Writ of Garnishment was sent via facsimile and first class mail, postage prepaid on the 19th day of September, 2012, to the following:
Manuel Sanchez S. Nathan Park Sanchez Daniels & Hoffman Michael S. Kim 333 Wacker Drive, Suite 500 Kobre & Kim LLP Chicago, IL 60606 800 Third Avenue 312.641.1555 New York, New ...