Free Motion to Dismiss - District Court of Colorado - Colorado

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

Document 116

Filed 11/28/2005

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-N-2440 (BNB) MATTHEW ARAGON, Plaintiff, v. LIFE QUOTES, INC., Defendant ______________________________________________________________________________ STIPULATED MOTION FOR DISMISSAL OF ATTORNEY LIEN DISPUTE ______________________________________________________________________________ Comes now, Stuart D. Mann of the LAW OFFICE OF STUART D. MANN, LLC, on behalf of Matthew Aragon, and Patricia S. Bangert, on behalf of herself, and they jointly submit this motion for dismissal of attorney lien dispute, and as grounds state as follows: 1. The parties have arrived at an agreement to fully and finally settle the attorney lien

dispute as set forth in the attached Mutual Settlement Agreement and General Release of All Claims (Exhibit A). 2. On September 29, 2005, the Court ordered that $36,519.98 of the settlement proceeds

in the above captioned case be held in the Law Office of Stuart D. Mann, LLC trust account pending further Order of the Court. 3. This matter having been settled, the parties request that the Court issue an order

allowing the Law Office of Stuart D. Mann, LLC to disburse funds in accordance with the Mutual Settlement Agreement and General Release of All Claims, and more specifically to release to Patricia 1

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

Document 116

Filed 11/28/2005

Page 2 of 2

Bangert, Esq. the sum of $21,000, and the balance of the funds to Plaintiff and his attorney, Stuart D. Mann. Wherefore Plaintiff Matthew Aragon and Attorney Patricia S. Bangert respectfully request that this Court grant this motion for dismissal of attorney lien, that the December 2, 2005 evidentiary hearing be vacated, and that the $36,519.98 held in trust be disbursed with $21,000.00 paid to Patricia S. Bangert as full and final settlement of her attorney lien. Dated: November 28, 2005 Respectfully submitted,

s/Stuart D. Mann Stuart D. Mann Law Office of Stuart D. Mann, LLC 12202 Airport Way, Suite 170 Broomfield, Colorado 80021 Telephone: 303-991-2233 FAX: 303-991-1895 E-mail: [email protected] Attorney for Plaintiff Matthew Aragon Stuart D. Mann

s/Patricia S. Bangert Patricia S. Bangert Special Counsel to Lohf, Shaiman, Jacobs, Hyman & Feiger, P.C. 950 South Cherry Street, Suite 900 Denver, Colorado 80246 Telephone: 303-753-9000 FAX: 303-753-9997

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