Dena J. Ulisano v. Frederick Ulisano, III, a/k/a Rick Ulisano and Moredirect, Inc.

We write to address appellant’s claim that the head of family exemption from a continuing writ of garnishment is not available to debtors residing out of state. After a 1993 amendment to the applicable statute, the statutory exemption applies to Florida residents and non-residents alike.

Dena Ulisano (“Creditor”) obtained a final judgment against Frederick Ulisano III (“Debtor”). To collect on the judgment, Creditor secured the issuance of a continuing writ of garnishment pursuant to section 77.0305, Florida Statutes (2013). The writ ordered Debtor’s employer, Mor-edirect, Inc., to withhold no…