No reason exists why the judgment in this cause should not be paid by defendant.

Defendant is indebted to plaintiff in the amount stated in the judgment.

Plaintiff properly filed and served post-judgment interrogatories on defendant.

Defendant received the post-judgment interrogatories from plaintiff more than 31 days ago. 

Defendant failed to answer post-judgment interrogatories within 31 days of service of same. 

Defendant has no valid reason or excuse for failing to answer the post-judgment interrogatories. 

Defendant refuses to answer the post-judgment interrogatories in order to conceal assets from levy. 

Defendant consents to the appointment of Tony Savarese as receiver in this case.

No exemptions are claimed as to any property owned by the defendant. 

Defendant owns collectable accounts receivable.

Defendant continues to generate business revenue.

Defendant owns stock.

The stock referred to in the preceding request is not exempt from attachment, execution, or seizure. 

Defendant has an active bank account.

The bank account referred to in the preceding is not a trust account.

Defendant has sufficient net worth to pay the judgment.

Defendant has the ability to pay the judgment, but has chosen not to pay.

Defendant owns real property, other than a homestead, which is sufficient to satisfy the judgment. 

No exemption is claimed as to the real property referred to in the preceding request.

Defendant owns personal property.

Defendant does not claim an exemption to the personal property referred to in the preceding request.

Though plaintiff has attempted to obtain payment of the judgment, Defendant has refused to discuss payment either by lump-sum payment or by installment payments.