Bergstrom

FACTS AND PROCEDURAL BACKGROUND

I. Facts

A. Underlying judgment In 2007, a Nevada state court entered a $2.1 million judgment against Northamerican Sureties, Ltd. (Northamerican) and Robert S. Michaels (Michaels). By April 2019, the amount of the judgment—with interest and costs—had blossomed to $4,064,012.61. B. Attempts to collect on judgment 1. Tying the bank accounts to the judgment debtor In August 2007, Crystal Bergstrom (plaintiff) was assigned the judgment, thereby stepping into the shoes of the judgment creditor. In 2019, plaintiff learned that Michaels’ wife—Cheryl Pitcock (Pitcock)—was the sole or coholder of two Los Angeles- based bank accounts at Zions Bancorporation, N.A. (Zions). As of April 1, 2019,2 the bank account ending in 1130 had a balance of $117,372.35, and the bank account ending in 9928 had a balance of $638.62.

Unless otherwise indicated, all further date references are to the year 2019.

3 At that time, Corporation Service Company (CSC) was acting as Zions’s agent for service of process for California-based matters. On March 29, plaintiff obtained a writ of execution in the amount of $4,944,759.25 from the Los Angeles Superior…