Free Motion to Exonerate - District Court of Arizona - Arizona

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

JOSEPH C. DOLAN, ESQ. (007376) 1650 North 1st Avenue Phoenix, Arizona 85003 (602) 266-7667 Attorney for Plaintiff IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA VILLAGE SQUARE AT WESTBROOK VILLAGE, an Arizona corporation Plaintiff, vs. STATE FARM FIRE AND CASUALTY COMPANY; ABC CORPORATIONS I-X; JOHN DOES I-X, Defendants. CV03-2515-PHX-HRH MOTION TO RELEASE / EXONERATE BOND

Plaintiff Village Square at Westbrook Village, by and through its attorney undersigned, hereby requests that this Court enter its order exonerating the bond paid by plaintiff with reference to the appeal of the above caption matter. INFORMATION ABOUT BOND 1. 2. 3. Name of Person entitled to have bond exonerated/released: Joseph C. Dolan, Esq. Amount of Bond: $455.00

Date Bond was Posted: May 17, 2006

REASONS BOND SHOULD BE EXONERATED/RELEASED This matter was on appeal to the United States Court of Appeals, Ninth Circuit, and was recently settled and dismissed (July 19, 2006) before any briefs were filed. Settlement included the parties bearing their costs. Plaintiff respectfully requests that this Court enter its order requiring the Clerk of the U. S. District Court to exonerate/release the bond to its attorney, Joseph C. Dolan, Esq.

Case 2:03-cv-02515-HRH

Document 86

Filed 09/14/2006

Page 1 of 3

1 2 3 4 5 6 7 8 9 10 11

RESPECTFULLY SUBMITTED this 14th day of September, 2006.

By

s/Joseph C. Dolan 007376 JOSEPH C. DOLAN, ESQ. 1650 North 1st Avenue Phoenix, Arizona 85003 Attorney for Plaintiffs

JOSEPH C. DOLAN

1650 North First Avenue Phoenix, Arizona 85003

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

2 Case 2:03-cv-02515-HRH Document 86 Filed 09/14/2006 Page 2 of 3

1 2 3 4 5 6 7 8 9 10 11

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on September 14, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: Ralph E. Hunsaker, Esq. THE CAVANAGH LAW FIRM 1850 North Central Avenue, Suite 2400 Phoenix, Arizona 85004 Attorneys for State Farm

I HEREBY CERTIFY that on September 14, 2006 I served the attached document by mailing a copy of the following: Honorable H. Russel Holland United States District Judge 222 West 7th Avenue ­ No. 54 Anchorage, Alaska 99513

JOSEPH C. DOLAN

1650 North First Avenue Phoenix, Arizona 85003

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27

s/Joseph C. Dolan, Esq. 007376 Attorney

3 Case 2:03-cv-02515-HRH Document 86 Filed 09/14/2006 Page 3 of 3