Orso v. Bennett, 2:21-mc-00013

Orso sought post-judgment writs of garnishment in the Middle District of Florida to collect a 2017 federal-court judgment against Ellen Bennett for $55,528.33 (net winnings plus prejudgment interest); post-judgment interest accrues under 28 U.S.C. § 1961.
Orso registered the foreign judgment and moved for writs to Bank of America, N.A. and JP Morgan Chase Bank, N.A., asserting each garnishee may be indebted to or possess property of Bennett sufficient to satisfy the judgment.
Federal Rule of Civil Procedure 69 directs that execution procedures follow state law; Florida garnishment statutes (Fla. Stat. § 77.01 et seq.) therefore govern the proceedings.
Florida law requires specific contents in a writ, a garnishee answer within 20 days stating indebtedness or possession of defendant’s property, and a statutorily prescribed "Notice to Defendant" when the defendant is an individual.
Orso’s proposed writs included a notice that did not comply with Fla. Stat. § 77.041, and his proposed writs contained extra pages the court found improper.
The court granted the motions, directed the clerk to issue the writs using only the first two pages of the proposed forms, ordered attachment of the court’s compliant Notice to Defendant, and instructed Orso to comply with Florida garnishment procedures and service requirements; the court also noted a likely typographical error concerning which party must advance $100 to the garnishee.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether clerk should issue writs of garnishment to BOA and Chase to satisfy the registered judgment	Orso asked the court to issue writs to both banks for the full judgment amount	No response from Bennett in the record	Granted; clerk directed to issue writs to both garnishees
Whether the form notice attached to the proposed writs complied with Fla. Stat. § 77.041	Orso submitted his form of notice with the proposed writs	No opposition from Bennett	Court found the proposed notice noncompliant and ordered the court’s statutory Notice to be attached
Whether all pages of the proposed writ forms should be issued	Orso submitted multi-page proposed writs (Docs. 2-1, 3-1)	N/A	Only pages 1–2 of each proposed writ shall be used; pages 3–5 must be deleted
Which party must advance $100 to the garnishee under Fla. Stat. § 77.28	Orso’s filings stated the defendant acknowledges obligation to compensate the garnishee $100	N/A	Court observed this appears to be a typographical error; statute requires the applicant (Orso) to advance $100 to the garnishee

None — the opinion relies on the Federal Rules of Civil Procedure and Florida statutes rather than reported case law.