PS Bus. Parks, L.P. v. Deutsch & Gilden, Inc.
Annotate this CasePS Business Parks, LP obtained a judgment against Deutsch & Gilden, Inc. for its failure to pay a lease. PS Business, naming Deutsch as debtor, filed a garnishment summons naming SunTrust Bank as garnishee. SunTrust filed two checks with the circuit court. The first check was drawn from an account titled to Deutsch, and the second check was drawn from an account titled to G&D Furniture Holdings, Inc. G&D Filed a motion to quash the garnishment of its account because it was not a party to the underlying action. The account was a master account participating in a “treasury management service” which, in a “zero balance account arrangement,” drew money each day from Deutsch’s account into the master account and moved funds from that master account to Deutsch’s account on an as-needed basis. The circuit court granted G&D’s motion to quash and ordered payment from the Deutsch account. The Supreme Court (1) affirmed the circuit court’s decision to quash garnishment of the G&D master account; and (2) held that the circuit court erred by not considering evidence of funds in Deutsch’s account during the period of time between service on SunTrust of the garnishment summons and its return date.
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