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This profile includes reviews for Messerli & Kramer's headquarters and its corporate-owned locations. To view all corporate locations, see Find Local Branches.

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  Messerli & Kramer

  50 S 6th St Suite 2300 Minneapolis, MN 55402

• 

  Messerli & Kramer

  525 Park St Ste 130 Saint Paul, MN 55103-2180

• 

  Messerli & Kramer

  3033 Campus Dr Ste 250 Plymouth, MN 55441-2662

Review Details

• Review fromTom S

  Date: 11/10/2025

  1 star
  Not sure how they can live with themselves. Missed one payment and they drained my high school aged child's account to get the remaining due well before the payment plans due date.

  Messerli & Kramer

  Date: 11/12/2025

  Mr. ********** is not a customer nor client of ********************** & ******************.  Furthermore, Mr. ********** is not a customer of ********************** & ******************'s clients; he does not have an account with them.  Mr. ************ spouse, *****, does have an account in which she last made a payment in March 2025 (thereby missing 8 payments, not one).  Thereafter, the court entered judgment in September which likewise remains unpaid.  The bank garnishment attached funds where the judgment-debtor is listed as an owner, Messerli & Kramer is not privy to the deposits in a judgment-debtor's account.  Mr. ************ review is unfairly and demonstrably false.

• Review fromJessica H

  Date: 10/23/2025

  1 star
  Back in January, they garnished my savings account for the full amount owed. My bank sent them the response that the money is on hold(in ND you need a 2nd court order to payout the garnishment) the next day. 2 weeks later they started garnishing my paychecks. When I called, they said they couldn't stop the garnishment of the paychecks until they hear from my bank. Had my bank send them another letter letting them know they still had the funds held. M/K did NOTHING. Paycheck garnishment was completed in May and still the money wasn't collected from either bank or job. I have called them almost weekly since 6/1 just to get them to do something. Again they did NOTHING...BUT got ANOTHER garnishment on my remaining bank accounts in July which brings the total to $7,930 for one $3,860 debt. I was recently told on 10/3 that the 1st order to pay(received 9/26) was incorrect and they had to send a 2nd request to the court on 10/1. Today when I called they told me that the 2nd order to pay wasn't sent till 10/21. Even though they are fully aware of the 3 garnishments, how much is held, and how long they've had this processing...they still take weeks or months to do any work and charge interest/fees. 10 months later...I am still waiting for it to be paid and my money back. How is waiting 9 months to request an order to pay, fair practice?

• Review fromJamie A

  Date: 10/19/2025

  1 star
  I believe that this attorney's office is in violation of laws regarding Credit/Repayment/Collections The debt that they are attempting to collect is more than 10 years old and one of the documents provided to me, and my employer is a court file with a signature date of 2015 in ****************. I did not move to WI until 2016. This stands out among other things.

  Messerli & Kramer

  Date: 10/23/2025

  Ms. ******* is not a customer of ********************** & ******************, but rather she is an adverse party in a lawsuit filed by one of its clients.  Judgment was entered against Ms. ******* on October 27, 2015, by Dakota County District Court. Thereafter, on September 05, 2019, this judgment was transferred to Barron County Circuit Court and docketed there. Minnesota civil judgments are valid for ten years. Minn. Stat. ******, Minn. Stat. ******. Wisconsin civil judgments are valid for twenty years. Wis. Stat. ******. As such, the judgment entered against Ms. ******* is not barred by any statute of limitations. We ask that Ms. ****** forward any future questions, comments, or concerns to Messerli & Kramer *******************, at ************************************************, or by phone, at **************.

• Review fromBrett T

  Date: 10/08/2025

  1 star
  This company was a nightmare to deal with. I spoke to several different people getting a different amount from every person I spoke to. They called my number but had the wrong customer. After I told them the mailing address and last four they told me none of that matched their records. I overpaid them and it took them over a month to send me the refund money.

  Messerli & Kramer

  Date: 10/09/2025

  This person is not a customer of the business.  There is insufficient information provided to identify the account referred to in the complaint.  We cannot respond to a complaint without complete information.

• Review fromMad M

  Date: 07/30/2025

  1 star
  Took all my money from my bank account zero warning I am the co applicant on a loan for a vehicle the primary had already been getting garnished to pay back the loan *************************************************************************************************** and wiped out my bank account leaving me with no money to pay any bills rent..Im livid.This is unprofessional and unexceptionable. Ive never received any court papers at all not one notice that they were gonna do this to me called them and all the man could say was call is being recorded you own the debt unfortunate but we can take all your moneyso Im working for nothing basically FOR BEING A CO APPLICANT

  Messerli & Kramer

  Date: 07/31/2025

  Mad Mad is not a name associated with any account in our law firm.  Furthermore, Messerli & Kramer represents clients.  It did not garnish any bank account, the Plaintiff in the lawsuit garnished as permitted under the law.

• Review fromS. B.

  Date: 07/29/2025

  1 star
  ?? Consumer Alert: **** Funding Weaponizes Lawsuits through ******************************* Reporting Against Disabled Victims of Identity Theft ??

  Messerli & Kramer

  Date: 07/31/2025

  Messerli & Kramer is a law firm that represents clients and pursues appropriate legal remedies.  Messerli's client alleges that Ms. ***** is its consumer who defaulted on her obligation to repay amounts she borrowed.  When parties disagree about the facts in a lawsuit, the court resolves the dispute.  Furthermore, the litigation process also gives the parties the opportunity to develop and discover the facts.  Based upon the facts developed in Ms. ******* case, notably her personal and financial hardship, the Plaintiff dismissed the case.  Ms. ******* allegation that "LVNV Funding Weaponizes Lawsuits through Messerli and Kramer" is nonsensical and unsupported by the facts.

  S. B.

  Date: 08/02/2025

  ******************************************** response is false, defamatory, and a continuation of their bad-faith conduct. I have never lived at the Georgia address tied to the fraudulent account, and their own court evidence confirmed this. My credit files have been locked, frozen, and fraud-alerted since 2021. The fraudulent account was inserted in mid-2024, and I immediately disputed it. Instead of validating the debt as required under the ****** they sued almost immediately, violating both the ***** and FCRA by weaponizing false credit reporting against a disabled identity theft victim.The case was dismissed only after I filed counterclaims and a motion for sanctions, proving they sought to avoid accountability for their misconduct. Their claim that I defaulted is false and directly contradicted by the record. This complaint exists because ******************************************* engages in harassment, retaliation, and knowingly frivolous lawsuits, and their response only confirms their ongoing abuse.

  S. B.

  Date: 08/02/2025

  ******************************************** response is false, defamatory, and a continuation of their bad-faith conduct. I have never lived at the Georgia address tied to the fraudulent account, and their own court evidence confirmed this. My credit files have been locked, frozen, and fraud-alerted since 2021. The fraudulent account was inserted in mid-2024, and I immediately disputed it. Instead of validating the debt as required under the ****** they sued almost immediately, violating both the ***** and FCRA by weaponizing false credit reporting against a disabled identity theft victim.The case was dismissed only after I filed counterclaims and a motion for sanctions, proving they sought to avoid accountability for their misconduct. Their claim that I defaulted is false and directly contradicted by the record. This complaint exists because ******************************************* engages in harassment, retaliation, and knowingly frivolous lawsuits, and their response only confirms their ongoing abuse.

  Messerli & Kramer

  Date: 08/06/2025

  The previous response provided to Ms. ****** concerns was not false, defamatory, or made in bad-faith. The Honorable Judge ****** ********* denied Ms. ****** motion on October 03, 2024, dismissing her requests for sanctions, injunctions, and other relief. Our client, the plaintiff in the action against Ms. ****** voluntarily dismissed the action against Ms. ***** after the court had issued its order denying her motion.  

  S. B.

  Date: 08/08/2025

  ******************************************** response is false, defamatory, and a continuation of their bad-faith conduct. I have never lived at the Georgia address tied to the fraudulent account, and their own court evidence confirmed this. My credit files have been locked, frozen, and fraud-alerted since 2021. The fraudulent account was inserted in mid-2024, and I immediately disputed it. Instead of validating the debt as required under the ****** they sued almost immediately, violating both the ***** and FCRA by weaponizing false credit reporting against a disabled identity theft victim.The case was dismissed only after I filed counterclaims and a motion for sanctions, proving they sought to avoid accountability for their misconduct. Their claim that I defaulted is false and directly contradicted by the record. This complaint exists because ******************************************* engages in harassment, retaliation, and knowingly frivolous lawsuits, and their response only confirms their ongoing abuse.

  S. B.

  Date: 08/08/2025

  ******************************************** response is false, defamatory, and a continuation of their bad-faith conduct. I have never lived at the Georgia address tied to the fraudulent account, and their own court evidence confirmed this. My credit files have been locked, frozen, and fraud-alerted since 2021. The fraudulent account was inserted in mid-2024, and I immediately disputed it. Instead of validating the debt as required under the ****** they sued almost immediately, violating both the ***** and FCRA by weaponizing false credit reporting against a disabled identity theft victim.The case was dismissed only after I filed counterclaims and a motion for sanctions, proving they sought to avoid accountability for their misconduct. Their claim that I defaulted is false and directly contradicted by the record. This complaint exists because ******************************************* engages in harassment, retaliation, and knowingly frivolous lawsuits, and their response only confirms their ongoing abuse.

  S. B.

  Date: 08/08/2025

  BBB Consumer Complaint Response Against: *****************, ******************************************** P.A., Gurstel Law Firm, P.C., **************************, and all affiliated, successor, or assignee entities.I, ******* *****, a disabled pro se litigant, hereby issue this public and permanent cease-and-desist demand against *****************, ******************************************** P.A., Gurstel Law Firm, P.C., **************************, and all affiliated, successor, or assignee entities, based on extensive violations of state, federal, constitutional, and civil rights laws, as well as the Americans with Disabilities Act ***** and the Nebraska Consumer Protection Act.Summary of Misconduct:1. Filing and refiling multiple fraudulent lawsuits against me over an identity theft debt, in violation of the Fair Debt Collection Practices Act (FDCPA), 15 ****C. 1692 et seq., and the Fair Credit Reporting Act (FCRA), 15 ****C. 1681 et seq.2. Accessing my locked, frozen, and fraud-alerted credit reports multiple times without authorization, in violation of FCRA 604(a).3. Inserting fraudulent tradelines into my credit reports after lawsuits were dismissed, including in December 2024, constituting unauthorized dissemination of personal information and retaliation for disputes.4. Contaminating my credit files with fraudulent addresses, including a Georgia address I have never resided at, damaging my credit integrity and causing ongoing harm.5. Commingling my personal information with unrelated accounts and disseminating it to third parties, including alleged original creditors, without my consent.6. Retaliating against me immediately after I disputed fraudulent accounts, suing not once but twice in bad faith.7. Engaging in conduct that constitutes Intentional Infliction of Emotional Distress (IIED), as recognized in ****** *. **********************, 598 F. Supp. 2d 1049 (N.D. **** 2009), where harassment over invalid debt resulted in a $500,000 jury *********** ****************** Invoked:- FDCPA, 15 ****C. 1692c, 1692d, 1692e, 1692f (harassment, false representations, unfair practices).- FCRA, 15 ****C. 1681b, 1681n, 1681o, 1681s-2 (unauthorized access, failure to ensure accuracy, improper reporting after dispute).- **** 42 ****C. ***** (retaliation against a disabled individual asserting their rights).- Nebraska Consumer Protection Act, Neb. Rev. ***** ******* to ******* (unfair and deceptive practices).- Nebraska Identity Theft Passport and Protection Laws, Neb. Rev. ***** ****** to ******.- Civil Rights Act, 42 ****C. 1983 (deprivation of constitutional rights under color of law).- Due *************** Protection Clauses of the 14th Amendment to the **** Constitution.Permanent Cease-and-Desist Demand:Effective immediately, all above-named entities and their affiliates are hereby ordered to permanently cease and desist from:1. Initiating or pursuing any litigation, arbitration, or collection activity against me on any alleged debt, whether valid, fabricated, assigned, purchased, or otherwise claimed.2. Accessing, retaining, disseminating, or sharing any of my personal, financial, or commingled information.3. Reporting or re-reporting any tradeline or account to any credit reporting agency.Mandatory Data Deletion Demand:All above-named entities must:- Permanently delete all personal, financial, and commingled data relating to me from their systems.- Instruct all third parties with whom such information has been shared to also permanently delete such data.- Provide written certification of full deletion and third-party compliance within 30 days.Willful Misconduct Damages Clause:Any violation of this public, permanent cease-and-desist and data deletion order shall constitute willful misconduct. For each and every occurrence, the violating party shall be liable for statutory, compensatory, and punitive damages in an amount no less than $50,000 per incident, plus attorneys fees, costs, and any other relief available under applicable law. This applies to all prohibited conduct defined herein, including contact, data retention, dissemination, credit reporting, and litigation activity.Enforcement:Violation of this notice will result in additional immediate filings with the ************************************, ************************, Nebraska Attorney Generals Consumer Protection Division, and the **** ********************* Civil Rights Division, along with applicable state bar disciplinary boards.This statement serves as a permanent, public record of my legal position, applicable to all past, present, and future cases or claims.Signed,******* *****

  Messerli & Kramer

  Date: 08/13/2025

  Messerli & Kramer is a law firm that represents clients.  Ms. ***** is not our client.  Messerli & Kramer respectfully disagrees with Ms. ******* allegations as did the court.  Ms. ******* continued dissertation is inappropriate and further response is not warranted.

  S. B.

  Date: 08/15/2025

  Public records from two separate debt collection cases brought against me by a client of ******************************************* reflect the following: ******************************************* or their client failed to appear for scheduled hearings. In both cases, their client did not respond to properly served discovery requests, interrogatories, or requests for production. In one case, my motion for summary judgment was denied due to a procedural filing deficiency under court rules. I was a self-represented (pro se) litigant at the time and not familiar with the technical requirements that trained attorneys follow. The denial was not a ruling on the merits of the claims, and the case was later dismissed. In the other case, ******************************************* dismissed the lawsuit before it could proceed to a hearing, after I filed formal defenses and discovery demands.Their prior BBB response suggested that the court rejected my defenses on the merits. That is incorrect. The denial of my motion for summary judgment was explicitly procedural and not a determination that their claims were valid. This distinction is confirmed by the subsequent dismissal of the ******* Experian credit file also shows four credit inquiries by their client between May and September 2024. These occurred while my credit files were locked, frozen, and under active fraud alerts, and while the disputed accounts were the subject of identity theft reports and bureau disputes.I reiterate my prior written and public demands for this firm and its client to:1. Permanently cease all litigation, credit reporting, or collection activity in my name.2. Permanently delete all personal data, including any commingled information added to my file, and any information shared with third parties.3. Confirm in writing that these actions have been completed.These requests are consistent with my rights under the Fair Credit Reporting Act (15 U.S.C. 1681 et seq.), the Fair Debt Collection Practices Act (15 U.S.C. 1692 et seq.), and the *****-*****-****** Act (15 U.S.C. ********), which provide for the protection, accuracy, and confidentiality of personal consumer information.If these demands are not met, I will be submitting updated documentation to the ************************************ for further review.**All statements above are supported by publicly available court filings, dismissal notices, official credit bureau records, and identity theft reports. This statement is provided solely to correct the record with accurate, documented information.

  S. B.

  Date: 08/21/2025

  **** and BBB FEEDBACK RESPONSE Complainant: ******* ***** Against: ******************************************** P.A.; *****************; **************************, L.P.; Gurstel Law Firm, P.C.; Credit ********* N.A.; ******************; and all affiliated, parent, subsidiary, assignee, successor, or colleague entities.Introduction and Purpose This submission serves as my formal and final feedback response to the ************************************ regarding the above-named entities. Because the **** feedback form does not allow attachments, this document contains all relevant details, quotations, factual corrections, and demands in full. It is intended as a permanent, public, and enforceable record of my legal position, supported by federal and state law, constitutional protections, and extensive documented history.I am a disabled, pro se litigant who has been repeatedly and unlawfully harassed through fraudulent lawsuits, false credit reporting, unauthorized access of my credit files, and the continued dissemination of my personal information despite fraud alerts, disputes, cease and desists, and identity theft reports. The pattern is ongoing, coordinated, and constitutes reprisal and escalation for exercising my rights.Misrepresentations by Respondents Both in BBB responses and **** complaints, ******************************************** acting for **** Funding, made false and defamatory claims:False claim of default. I never defaulted on the alleged debts. Court records confirm that the Georgia address tied to the fraudulent accounts is not mine. Their own evidence contradicted their claims.Improper attempt to smear my submissions as a dissertation or inappropriate. In BBB and related responses, ******************************************* characterized my factual, source-grounded submissions as a dissertation and inappropriate. That is false and retaliatory framing intended to belittle, chill, and discredit a consumers detailed reporting of abuse. Because the **** portal does not allow attachments, a comprehensive narrative is the only way to present the underlying dates, quotes, and record citations. Efforts to trivialize or discourage this reporting are themselves indicia of unfair, deceptive, or abusive acts and practices under the ****-***** Act (12 U.S.C. ?5531) and do nothing to rebut the documented record. This is not retaliation by me; it is protected petitioning and consumer reporting activity in response to the respondents continued reprisal and escalation.False claim that dismissals were due to my hardship. They repeatedly asserted that cases were dismissed out of recognition of hardship. This is demonstrably false. Dismissals occurred only after they failed to appear for hearings, refused discovery, and I filed counterclaims and motions for sanctions. These were tactical withdrawals to avoid rulings on misconductnot compassion. If hardship was truly the reason, no lawsuit would ever have been refiled. Yet a new firm later refiled the same claims, proving that hardship was a false narrative used to obscure misconduct.False claim that court rulings supported them. My motion for summary judgment in one case was denied procedurally, not on the merits. ******************************************* misrepresented this as a substantive loss. The case was later voluntarily dismissed. In another case, they voluntarily dismissed pre-hearing after I asserted defenses and discovery.Contradiction with third lawsuit. After ******************************************* withdrew, a new law firm refiled the same claims, while still claiming to acknowledge hardship. This makes their position internally inconsistent and underscores the bad-faith, retaliatory nature of the litigation.Pattern of Harassment and Reprisal Multiple Lawsuits. Three lawsuits were filed over identity-theft accounts. Two dismissed without prejudice (exploited as loopholes), and a third refiled by a new law firm on the same account. A fourth is now threatened over a new fraudulent account inserted in early 2025.Unauthorized Credit Access. **** Funding and its agents accessed my locked, frozen, and fraud-alerted credit files at least four times between MaySeptember 2024 and again in December 2024.Fraudulent Reinsertions. Following dismissals, ****************** tradeline appeared despite prior removals of the **** tradline, while **** Funding accounts were deleted only after I forced removal. A new **** tradeline appeared in January 2025continuing the cycle.Commingling and Data Contamination. My credit reports were polluted with false addresses (including the Georgia address I have never lived at) and with unrelated accounts, commingling my identity with others.Reprisal After Disputes. Each time I disputed fraudulent accounts, **** Funding and its law firms escalated to litigation rather than validation. This is not consumer retaliationit is my lawful defense against reprisal and escalation by debt buyers exploiting litigation and credit reporting as weapons.Courtroom Threats. In the third case, opposing counsel threatened me with refiling the dismissal with prejudice case if I did not abandon my claims.Violation of Cease-and-Desist Orders. Since 2024, I have issued numerous cease-and-desist demands. These have been repeatedly violated, proving willful disregard for the ********* Rights and Violations This misconduct violates multiple federal and state laws, including:FDCPA (15 U.S.C. 1692 et seq.): harassment, false representation, unfair practices, and illegal lawsuits.FCRA (15 U.S.C. 1681 et seq.): unauthorized access (604(a)), failure to ensure accuracy, re-reporting disputed accounts, contamination of credit files.ADA (42 U.S.C. *****): retaliation against me as a disabled individual asserting my rights.Nebraska Consumer Protection Act (Neb. Rev. ***** ******* to 59-1623).Nebraska Identity Theft Protection Laws (Neb. Rev. ***** ****** to 28-640).Civil Rights Act, 42 U.S.C. 1983: deprivation of rights under color of law.Constitutional Protections: Due Process and Equal Protection under the 14th Amendment.IIED: Intentional Infliction of Emotional Distress, consistent with ****** *. **********************, 598 F. Supp. 2d 1049 (N.D. **** 2009).Permanent Cease-and-Desist Demands Effective immediately, ******************************************** LVNV Funding, *************************** Gurstel Law Firm, ***************, ******************, and all affiliated, parent, subsidiary, successor, assignee, colleague, or related entities are hereby ordered to:Permanently cease all litigation, arbitration, or collection activity against me on any alleged debt, whether valid, fabricated, assigned, purchased, or otherwise claimed.Permanently cease all access, retention, dissemination, or sharing of my personal, financial, or commingled information.Permanently cease all reporting or re-reporting of any tradeline or account in my name to any credit bureau.Permanently delete all personal and commingled data from their systems and databases, and instruct all third parties to do the same.Provide written certification of full deletion and third-party compliance within 30 ******* further communications are permitted except a single written certification of compliance. Any other contactincluding collection letters, fabricated evidence, or delay tacticsshall be treated as willful misconduct.Willful Misconduct Damages Clause Any violation of these demands shall constitute willful misconduct. Each violation will subject the offender to statutory, compensatory, and punitive damages of no less than $50,000 per incident, plus attorneys fees, costs, and additional relief available at law.Enforcement and ****s Duty If noncompliance continues, I will escalate immediately to: the FTC, Nebraska Attorney Generals Consumer Protection Division, the ************************** Civil Rights Division, and applicable state bar disciplinary boards.The **** is not a passive observer. Under 12 U.S.C. 5531, it is mandated to intervene against unfair, deceptive, or abusive acts. Allowing these entities to continue unchecked would amount to regulatory abdication. Enforcement is not discretionary hereit is a statutory duty.Conclusion I demand permanent, all-encompassing protection. The misconduct against me is not a one-time error; it is a deliberate, repeated, and retaliatory scheme. My rights under the *****, ****, ***, state identity theft laws, and the Constitution guarantee me the relief demanded here.This feedback response is a final, public record. Compliance is not optional. Noncompliance will trigger immediate enforcement action.This matter has been filed with the ************************************. Including it here for consumer and public reference.

• Review fromDannielle H

  Date: 07/16/2025

  1 star
  Messerli and Kramer did not post my money to my account after several attempts to correct. I placed an incorrect reference number unknowingly and called to get answers. Its been since May and no one at M&K has followed thru. Today I was told they will start the correction. I will not hold my breath.

• Review fromShawn J

  Date: 06/24/2025

  1 star
  They are criminals do not trust them at all. They should be allowed to practice law period.

• Review fromMoises S

  Date: 05/22/2025

  1 star
  I have been harassed by this company, I have tried multiple time to settle this debt but it is impossible to get a representative willing to work with you instead of harass you. I requested to make a one time payment or a ****************************************************** confirming what we agreed , I have them my new phone number and address at the beginning nothing arrived the due date came in I called in multiple times left multiple voicemails no call back. Few days later I get a called from this company ay my work place, ******** IN EXTENSION 5638 accused me of disconnecting my line and not making a payment and threat that if I didnt do the payment within 5 days they were going to proceed with judgement, then she recognized she mis dialed the phone number when she tried to call me multiple times she said a few days ago, TODAY I called in because I requested this contract again sent to my email and AGAIN she ignored my request I called in today again she said it wasnt processed and that she couldnt called me because she didnt had my permission to do so. What a shady, unethical person she is, of course hang up on me and now I wasnt able to make my payment and it most likely I am going to receive a judgment notice, what a sad world we live, customer trying to solve their ******************** and this employee and company are just scammers. I am joining hundred of people having issues with *********** and will pursue legal actions.

  Messerli & Kramer

  Date: 05/27/2025

  M|K# 24-156579

  We respectfully disagree with Mr. *** ******** claim that he is being harassed; however, as a result of his allegation, we have updated his account to reflect that he does not wish to be contacted regarding his past due obligation to our client and will only provide legally required notices.  Mr. *** ****** can continue to make his monthly payments as agreed, however, if he misses a payment we will not reach out to him as a courtesy and will instead just proceed with our client's legal remedies.

• Review fromSelena H

  Date: 04/16/2025

  1 star
  ******************************************* is awful, I understand that I did not do my part but maybe I do not have the funds to even set up a payment plan. Living pay check to pay check.. They took everything that I had which was a little over 100 bucks in my savings account and maybe 200 bucks I my checking with a 100 surcharge fee... I was in the grocery with my small children having to tell them mommy's money is gone-- we couldn't get our needs..

  Messerli & Kramer

  Date: 04/17/2025

  Messerli & Kramer is not Ms. *********' creditor and did not take her money.  ******** account was garnished by her creditor after a judgment (Otter Tail County Court File Number 56-CV-25-544) was entered against her and not satisfied.  Messerli & Kramer attempted to set up an arrangement between Ms. ********* and her creditor prior to the garnishment.  Ms. ********* review is misdirected.