Defendant John Doe, by undersigned counsel, files this Motion to quash the Write of Garnishment and states:

  1. That judgment was entered on January 1, 2015
  2. That defendant has serious concerns about the service of process in this case
  3. That a writ of garnishment was issued against Bank of High Fees.
  4. That Defendant’s accounts with Bank of High Fees contain funds from a personal injury settlement reached in John Doe v. Jane Doe.
  5. That Defendant received a settlement in the amount of $$100,000. Ex. A. Settlement Check.
  6. That said settlement was deposited in the Bank of High Fees account 1192-82 on February 07, 2015. Ex. B. Deposit Slip
  7. That pursuant to Maryland Court and Judicial Proceedings section 11-504(b)(2)  (2)   “Money payable in the event of sickness, accident, injury, or death of any person, including compensation for loss of future earnings. This exemption includes but is not limited to money payable on account of judgments, arbitration, compromises, insurance, benefits, compensation, and relief. Disability income benefits are not exempt if the judgment is for necessities contracted for after the disability is incurred.”
  8. Therefore, Defendant’s settlement funds in the Bank of High Fees accounts are not subject to execution pursuant to a judgment.
  9. Therefore, the Writ of Garnishment should be quashed immediately

WHEREFORE, Defendant John Doe respectfully requests that this court :

  1. Enter an Order to Quash the Writ of Garnishment against Defendant’s accounts with the Bank of High Fees;
  2. Enter an Order directing Plaintiff to take all necessary steps to immediately release the lien on the Defendant account;
  3. And grant such and further relief as his cause may require.