United States District Court, W.D. Washington, Seattle
Honorable Richard A. Jones United States District Judge
matter comes before the Court on Defendant Mick Dadlani's
Motion to Quash Writ of Garnishment and for Award of Attorney
Fees and Costs. Dkt. # 5. For the reasons that follow, the
Court DENIES Dadlani's motion.
January 29, 2016, the United States District Court for the
District of Columbia entered a $687, 000 judgment in favor of
Plaintiff Briggitta Hardin, $676, 000 of which was against
Dadlani. Hardin v. Dadlani, C11-2052-RBW, Dkt. # 176
(D.C. Jan. 29, 2016).
16, 2016, Hardin registered the judgment in this Court as a
foreign judgment to be enforced against Dadlani. Hardin
v. Dadlani, C16-mc-66, Dkt. # 1 (W.D. Wash. May 16,
22, 2016, Hardin filed an application for writ of garnishment
to impose a lien on Dadlani's earnings from National
Securities Corporation, an entity located in Seattle. Dkt. #
1. The Court granted Hardin's request and entered an
order garnishing Dadlani's earnings in the amount of
$676, 046. Dkt. ## 2-3.
now moves to quash the writ of garnishment on the basis that
Hardin did not follow the proper procedure for filing a
foreign judgment in this Court. Dkt. # 5. Hardin opposes the
motion. Dkt. # 13.
contends that the writ of garnishment must be quashed because
Hardin failed to register the foreign judgment in accordance
with Washington's Uniform Enforcement of Judgments Act
(“UEFJA”), RCW 6.36.010, et seq. Under
the UEFJA, a plaintiff registering a foreign judgment must
comply with certain procedural requirements, which include
(1) submitting an affidavit that contains identifying
information about the judgment debtor and (2) notifying the
judgment debtor by mail that the foreign judgment was filed.
these state registration requirements are not required in
federal court when a plaintiff complies with the separate
registration process set forth under 28 U.S.C. § 1963.
federal registration statute provides, in relevant part:
A judgment in an action for the recovery of money or property
entered in any . . . district court . . . may be registered
by filing a certified copy of the judgment in any other
district . . . when the judgment has become final by appeal
or expiration of the time for appeal or when ordered by the
court that entered the judgment for good cause shown. Such a
judgment entered in favor of the United States may be so
registered any time after judgment is entered. A judgment so
registered shall have the same effect as a judgment of the
district court of the district where registered and may be
enforced in like manner. . . . The procedure prescribed under
this section is in addition to other procedures provided by
law for the enforcement of judgments.
28 U.S.C. § 1963. Dadlani emphasizes the last sentence
to contend that this statute necessarily exists in tandem
with state laws governing the registration of foreign
judgments. That sentence, however, applies ...