Free Motion for Disbursement of Funds - District Court of Colorado - Colorado

Case 1:03-rj-00025

Document 20

Filed 11/29/2005

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Case No. 03-RJ-00025 WEST DIRECT, INC., Plaintiff v. FBC MARKETING, LLC, Defendant.

STIPULATED MOTION FOR ORDER DISBURSING GARNISHED FUNDS The parties, by their undersigned counsel, hereby enter into the following stipulated motion for disbursement of garnished funds as follows:

1.

The parties are filing this stipulated motion seeking an order directing Garnishee,

Key Bank, to disburse $1,894.84 in garnished funds to counsel for Plaintiff. 2. In or about November of 2003, Plaintiff served Key Bank with the Writ of

Garnishment, a copy of which is attached hereto as Exhibit 1. Key Bank did not answer the Writ of Garnishment. The parties recently discovered that Key Bank is holding $1,894.84 pursuant to said writ of garnishment. See Exhibit 1. 3. The parties need the entry of an order directing Key Bank to disburse the

garnished funds to counsel for Plaintiff. A proposed form of order is submitted herewith.

Case 1:03-rj-00025

Document 20

Filed 11/29/2005

Page 2 of 2

WHEREFORE, the parties request an entry of an order directing Key Bank to disburse the garnished funds, as set forth above, and pursuant to the order submitted herewith, and for such other relief as the court deems proper. Dated this 11th day of November, 2005. BLOOM MURR & ACCOMAZZO, P.C. Duly signed original on file at the offices of Bloom Murr & Accomazzo, P.C. By: /s/ Michael G. Milstein Michael G. Milstein, Reg. No. 23833 410 Seventeenth St., Suite 2400 Denver, Colorado 80202 Phone: (303)534-2277 Fax: (303)534-1313 [email protected] Attorneys for West Direct, Inc. Dated this 11th day of November, 2005. ISSACSON, ROSENBAUM, WOODS & LEVY, P.C. Duly signed original on file at the offices of Issacson, Rosenbaum, Woods & Levy, P.C. By: /s/ Edward T. Ramey Edward T. Ramey, Reg. No. 6748 633 Seventeenth St., Suite 2200 Denver, Colorado 80202 Phone: (303)292-5656 Fax: (303)292-3152 [email protected] Attorneys for Family Buyers Club, LLC, Robert Makatura, Raymond Makatura, and International Magazine Service of the Rockies, Inc.

2