STATE OF WISCONSIN CIRCUIT COURT OUTAGAMIE COUNTY COVANTAGE CREDIT UNION, Plaintiff, v. ERIC WIERZCHOWSKI, Defendant. Case No. 23-CV-79 PLAINTIFF'S AMENDED NOTICE OF MOTIONAND MOTION FOR CONTEMPT Plaintiff, CoVantage Credit Union ("CoVantage") by their attorneys, Galanis, Pollack, Jacobs & Johnson, SC hereby moves the Court, the Honorable Mark J. McGinnis, or other assigned judge, presiding in their courtroom on November 3, 2025 at 9:00 AM at the Outagamie County Government Center, 320 S. Walnut Street, Appleton, WI 54911 for an Order finding the defendant in contempt of court. On March 20, 2023 the Plaintiff was awarded a judgment against the defendant for the return of the following collateral: 2017 Jeep Grand Cherokee – VIN: 1C4RJFBG0HC645792.1. The defendant has not made the collateral available and the failure to make the collateral available to the plaintiff is merits for this court to issue an order for contempt. 2. The defendant's failure to make the collateral available to the Sheriff when enforcing a writ of replevin is merits for this court to issue an order for contempt. That included with this motion is the sheriff report indicating collateral could not be located within the county. 3. It is the plaintiff's position that the collateral remains concealed at 825 S. Olson Aven, Unit G in Appleton, WI as that was the last known address for the defendant and remains the last known address. That if a search and seizure warrant is required, the plaintiff will separately so move. 4. Wisconsin Statute §943.84(2) indicates that the defendant cannot conceal, remove or transfer property with a security interest: 943.84  Transfer of encumbered property. (2) Whoever, with intent to defraud, does any of the following may be penalized as provided in s. 943.91: (a) Conceals, removes or transfers any personal property in which he or she knows another has a security interest; or (b) In violation of the security agreement, fails or refuses to pay over to the secured party the proceeds from the sale of property subject to a security interest. 5. There is no dispute that the plaintiff has a security interest in the collateral and further, there can be no dispute that the defendant is concealing, removed and transferred the property. 6. Whereby the plaintiff will agree to allow the defendant seven (7) days to provide the property to the Outagamie County Sheriff, or otherwise stay enforcement of an order for contempt. WHEREFORE: CoVantage Credit Union requests the Court enter an Order holding Eric Wierzchowski in contempt, actual attorney's fees and costs in filing this motion, and for such other relief as this Court deems just and proper. Dated: October 10, 2025 Galanis, Pollack, Jacobs & Johnson, S.C. By: /s/ electronically signed & dated Joshua J. Brady Attorney for CoVantage Credit Union 413 N. 2nd Street Suite 150 Milwaukee, WI 53203 (414) 271-9556 jbrady@gpjlaw.com FAIR DEBT COLLECTION PRACTICES ACT NOTICE Federal law (15 U.S.C. Section 1692) gives you 30 days after the receipt of this pleading to dispute the validity of the debt or any part of it. If you do not dispute the debt within that period, we will assume that the debt is valid. If you notify us within 30 days after the receipt of this correspondence that this debt or any portion thereof is disputed, we will, as required by law, obtain verification and proof of the debt and provide you with same, including a copy of any existing judgment. Also, if within the same 30 day time period, you request the name and address of the original creditor, if the original creditor is different from the current creditor, we will furnish you with that information as well. This advice pertains to your dealings with our law firm as a debt collector. IT DOES NOT AFFECT YOUR DEALINGS WITH THIS COURT, AND IN PARTICULAR IT DOES NOT CHANGE THE TIME IN WHICH YOU MUST RESPOND TO THIS MOTION. The Notice of Motion is a command under the court rules, not from our law firm, and you must follow its instructions even if you dispute the validity or amount of the debt. The advice in this correspondence also does not affect our law firm's relationship with the court. As a law firm, we may file papers in this bankruptcy according to the court's rules and the judge's instructions. WE ARE DEBT COLLECTORS AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. WNAXLP October 14 2025 LWIX0387685