Free Response in Opposition to Motion - District Court of Arizona - Arizona

1 Michael G. Helms — 014470
KOTHE & HELMS, P.C._ ‘
2 3200 North Central Avenue, Suite 1260
Phoenix, Arizona 85012
3, Telephone: (602) 358-2060
Fax: (602) 358-2055
4 .
Attorneys for Plaintiff Best Western
5 International, Inc. i
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IN THE UNITED STATES DISTRICT COURT t
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FOR THE DISTRICT OF ARIZONA
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Best Western International, Inc., an
9 Arizona non-profit corporation, No. CV 04-0661 PHX DGC
10 Plaintiff .
AFFIDAVIT OF COUNSEL IN
11 vs. OPPOSITION TO DEFENDANTS’ t
MOTION FOR RELIEF FROM
12 Bristol Inns, L.L.C., a Tennessee limited JUDGMENT
liability company; and Desiree Keithan,
13
Defendants.
14
15 STATE OF ARIZONA ) 2
) ss.
16 County of Maricopa ) ,
17 Michael G. Helms, being first duly sworn upon his oath, deposes and says: t
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19 1. I one of the attorneys for Plaintiff; Best Western Intemational, Inc., in
zo the above-entitled action. I make this affidavit upon personal knowledge.
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22 2. Pursuant to Best Western’s Application for Default Judgment herein, the
273 Court did enter default judgment on behalf of Best Western and against the defendants
24 herein on or about September 16, 2004.
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' Case 2:O4—cv-00661-DGC Document 17-2 Filed O9/20/2005 Page 1 of 2

1 3. On October 19, 2005, I did forward by United States mail a copy of the 1 `
2 default judgment entered herein to defendants Bristol Inns, LLC, and Desiree Keithan. A A
3 copy of said correspondence is attached hereto and incorporated herein. Such mail was
4 not returned to me as undeliverable, and was presumably delivered to the defendants.
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6 4. I did cause, with the assistance of counsel in Bristol, Termessee, certified 1
7 copies of the default judgment to be filed and docketed in the United States District Court p
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for the Western District of Virginia on or about May l0, 2005, and in the Bristol Circuit
9
10 Court in Bristol, Virginia, on or about May ll, 2005.
l l t I
it Dated this 20th day of September, 20Q I .
12 5 .1 Z 1
13 E ,
\
14 Michael G. Helms .
l5
16 SUBSCRIBED AND SWORN to before me this Qvwday of September 2005. I
18 V { i I
19 Notary Public l
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21 My Commission Expires: _
M . P
22 "‘ Mglnflgirnmission Expires
" " AUGUST 31, 2008
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Case 2:O4—cv—OO661-DGC Document_17-2 Filed O9/20/2005 Page 2 of 2 2
Z:\Best Western v. Bristol, Tenn\aflidav1t of counsel re motion for relief from judgmentdoc

Case 2:04-cv-00661-DGC

Document 17-2

Filed 09/20/2005

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Case 2:04-cv-00661-DGC

Document 17-2

Filed 09/20/2005

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