Free Motion to Intervene - District Court of Colorado - Colorado

Case 1:03-cv-02440-EWN-BNB

Document 99

Filed 09/13/2005

Page 1 of 3

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-cv-2440-EWN-BNB MATTHEW ARAGON, Plaintiff, v. LIFE QUOTES, INC. Defendant. ______________________________________________________________________________ MOTION TO PARTICIPATE IN HEARING ______________________________________________________________________________ The undersigned hereby requests leave to participate in the hearing set by the Court in this matter for September 29, 2005, as noticed in Document # 94, and, as grounds therefore, states as follows: 1. On August 23, 2005, the undersigned filed notice of an attorney's lien, based upon

amounts owed her for legal services and costs related to the above-cited matter. See Document #83 (Notice of Attorney's Lien). 2. The undersigned understands that a settlement has been reached in this matter.

See Documents #84 and #87. The undersigned further understands that it was represented to the Court during settlement negotiations that she had filed an attorney's lien in this matter. Id. 3. Both parties to this case have filed motions to enforce the settlement reached in

this matter. See Documents #84 and #87. This Court has ordered that a hearing be held on those motions on September 29, 2005. See Document #94. 4. Because of the undersigned's legal interest in the settlement proceeds, she wishes

to participate in the hearing regarding the motions to enforce the settlement.

Case 1:03-cv-02440-EWN-BNB

Document 99

Filed 09/13/2005

Page 2 of 3

5.

The undersigned has contacted counsel for the parties regarding their position on

this motion. Counsel for Defendant states that Defendant does not oppose this motion. Counsel for Plaintiff states that Plaintiff opposes this motion to the extent that the undersigned will address her lien. WHEREFORE, the undersigned respectfully requests that the Court grant her leave to participate in the hearing on the parties' motions to enforce the settlement agreement reached in this case. DATED this 13th day of September, 2005.

Respectfully submitted,

s/Patricia S. Bangert Patricia S. Bangert Attorney at Law 3773 Cherry Creek Drive North, Suite 575 Denver, Colorado 80209 Former Attorney for Plaintiff Matthew Aragon

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Case 1:03-cv-02440-EWN-BNB

Document 99

Filed 09/13/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on September 13, 2005, a true and correct copy of the foregoing was electronically filed with the Clerk of the Court using the CM/ECF system which sent notification of such filing to the following: Kristen L. Mix, Esq. and Stuart David Mann

s/Patricia S. Bangert
_______________________________