IN THE IOWA DISTRICT COURT FOR POTTAWATTAMIE COUNTY

SERVICE DOGS BY WARREN

RETRIEVERS, INC., F/K/A Case No. LACV111413
Guardian Angel Service Dogs, Inc.

Plaintiff,

vs.

MICHAEL SPIZZIRRI AND JEANA
SPIZZIRRI,

Defendants.

___________________________________


DEFENDANTS EMERGENCY MOTION FOR AN
ORDER FOR REDELIVERY

COMES NOW, Defendants, Michael and Jeana Spizzirri, (hereinafter Defendants), and files
this Emergency Motion for an Order for Redelivery and states as follows:
1. A Petition (Replevin) was filed on May 28, 2014 by the Plaintiff, Service Dogs by
Warren Retrievers.
2. Along with the Petition, an Application for Immediate Possession was also filed by the
Petitioner with a bond for $10,000.
3. On June 10, 2014, the sheriff removed the property, a dog, from the Defendants
possession and the animal was placed at a local veterinarian clinic until the Plaintiff could
pick up the dog.
4. The Defendants posted the bond on June 12, 2014 at which time they discovered that the
dog had been moved out of the state.
5. The Defendants have tried to communicate with the Plaintiffs attorney to arrange for the
return of the property which is a black female Labrador retriever, ID# 074*315*364 but
have had no success.
6. This is an Emergency because the dog is a medical device for the Defendants and their
minor child and the longer the dog is away from the Defendants, the more damage is
done to the dogs ongoing training.
WHERFORE, the Defendants request this Honorable Court for an Order demanding the
Plaintiff immediately return/release the dog to the Defendants or a Writ of possession so that the
Defendants can make arrangements to have the dog picked up at the Plaintiffs location by a
third party.
DATED this 13
th
day of June, 2014.
Respectfully submitted,
/s/ Michael Spizzirri /s/ Jeana
Spizzirri
Michael Spizzirri Jeana Spizzirri
199 E. Orchard Ave
Council Bluffs, IA 51503
402-990-3641
Jel1234@aol.com
DEFENDANTS