Eviction & Garnishment (Complete list of doc to ensure success)

[Ying B.]

I have a tenant who did not pay Sept rent and lease ends at end of Oct.  I requested my PM to file eviction from 9/12-9/23 but PM did not comply.  So I filed the Dispossessory myself on 9/26.  I have requested the PM to provide me with tenant ledger, email address, 3 day Pay or Quit notice PM said they issued but was not given.  I have filed a BBB complaint against the PM Sept 20 but PM has not given response yet.  I plan to follow through with eviction, obtain a judgment, proceed with Garnishment. Or if I do not get a money judgement, I will file a civil suit and garnish.  Unlike a lot of the investors who either dread legal proceedings, or think it is a waste of time, I actually am of a different mind set.  I will exercise any legal remedy available to me.  

This post is trying to ask you guys, is there a complete list of things I am entitled for from the PM now and when I do terminate with them?   If PM does not comply, what measures do you suggest I take to ensure I obtain the documents.  My attorney via Legal Shield made aware that the magistrate court does not allow subpoena. 

Please note: I decided to not terminate with the PM before the property is vacant but only take the eviction part of the duty from the scope of our agreement (this is because I can't get the PM to file evictions and I can't wait).  Additionally I do not have another resource that are lined up to do what this PM's job is for just the last bit of work (move out, account for Sec. Dep) and also it is not wise to do it myself.   This is why I keep the current PM at this juncture although they really have not protected my interest or followed my instruction.  The list I can think of is as follows, the first 3 of which I asked multiple times but was not given.  Number 4 I think I will have the most challenge but that does not have to be given right now.  

1. Email of Tenant ( I have phone # already)

2. Tenant Ledger

3.  Three day Pay or Quit notice sent by PM

4.Tenant employer info, and SSN that enable skip trace so we can garnish wages. 

5. Tenant renter insurance in case there is damage that I need to file using their insurance. 

Is there anything else I am missing that I should be asking through a demand letter sent by attorney?  My Legal Shield membership provides 1 demand letter per legal matter and unlimited questions, but the attorney asks me to give him a list of demands then he works from there.   

Thank you.