Filed: 4/22/2019 2:34 PM
`Vanderburgh Superior Court 6
`Vanderburgh County, Indiana
`IN THE VANDERBURGH SUPERIOR COURT
`
`Cause No. 82D03-1306-CC-2954
`
`STATE OF INDIANA
`
`COUNTY OF VANDERBURGH
`
`SS:
`
`Deaconess Hospital,
`Inc.
`
`vs.
`Mary L. Gilbert
`
`JNJ Foods, LLC
`
`Plaintiff,
`
`Judgment Defendant,
`
`Garnishee Defendant,
`
`PETITION FOR ISSUANCE OF NEW ORDER OF GARNISHMENT
`
`Plaintiff respectfully requests that the Court issue a new Order of Garnishment directing JNJ Foods, LLC
`to pay to Plaintiff the income or profits of Mary L. Gilbert that are in the hands of JNJ Foods, LLC. In support of
`this Petition, Plaintiff states as follows:
`
`The Court previously issued an Order of Garnishment ("Prior Order of Garnishment"), in accordance with
`Ind. Code§ 34-55-8-7, with respect to Mary L. Gilbert's income or profits that were in the hands of a third party.
`
`The Prior Order of Garnishment provides that the Judgment in this matter is a continuing lien upon the
`income or profits of Mary L. Gilbert, ***-**-3628.
`
`Upon information and belief, due to Mary L. Gilbert's change of employment, Mary L. Gilbert's income or
`profits are now in the hands of a new third party that is not named in the Prior Order of Garnishment.
`
`Upon information and belief, the new third party holding Mary L. Gilbert's income and profits is JNJ Foods, LLC,
`7000 Stonewick Dr., Newburgh IN 47630.
`
`In accordance with LC. § 34-55-8-7(h), the Court may issue a new Order of Garnishment without holding a
`hearing.
`
`WHEREFORE, Plaintiff, respectfully requests that the Court issue a new Order of Garnishment directing
`JNJ Foods, LLC to pay to Plaintiff the income or profits of Mary L. Gilbert that are in the hands of JNJ Foods,
`LLC.
`
`I hereby certify that the foregoing complies with the requirements of Trial Rule 5(G) with regard to information
`excluded from the public record under Administrative Rule 9(G).
`
`ory C. D kard, #30317-49
`KAHN, DEES, DONOVAN & KAHN, LLP
`501 Main Street, Suite 305
`Post Office Box 3646
`Evansville, Indiana 47735-3646
`Telephone: (812) 423-3183; Facsimile: (812) 423-3841
`Email: mdeckard@kddk.com
`54191
`
`

`

`CERTIFICATE OF SERVICE
`
`APR 2 2 2019
`, upon the following
`I certify that the foregoing document was served on
`Mary L. Gilbert via first-class U.S. mail, postage prepaid, addr-es-s-ed...,....-a-s """"fo__,.l.,....lo_w_s_, _ _ _ _ _ ,
`
`Mary L. Gilbert
`1003 N . Cherry St. Apt. B
`Mount Carmel IL 62863
`
`and upon JNJ Foods, LLC via certified mail, addressed as follows:
`
`JNJ Foods, LLC
`Attn: Payroll
`7000 Stonewick Dr.
`Newburgh IN 47630
`
`lf!!o~
`
`Kahn, Dees, Donovan & Kahn, LLP is a debt collector. Kahn, Dees, Donovan & Kahn, LLP is attempting to
`collect a debt and any information obtained will be used for that purpose.
`HKK/27000-910/54191
`
`