Plaintiff's motion for spousal support garnishment is denied without prejudice. Pursuant to CCP § 706.109, an earnings withholding order may not be issued against the earnings of the spouse of the judgment debtor except by court order upon noticed motion. The reason for this set forth in the Legislative Committee Comments: "Section 706.109 recognizes that despite the general rule that community property is liable for debts of a spouse [Family Code § 910(a)], community property earnings are unique and may not be liable in some situations." The earnings of a married person during marriage are not liable for a debt incurred by the person's spouse before marriage unless they are placed in a commingled account. Family Code § 911(a). There is no evidence before the Court that Karen Romano was married to the judgment debtor at the time the debt was incurred. The debt was incurred in February 2015 at the time the contract was made - when Defendants executed the personal guarantees - and not wh