Free Reply to Response to Motion - District Court of Arizona - Arizona

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mm Pa trick N. Ch ap an DDDADD ,._ GONCIARZ’ESQ,‘
NEVADA. UTAH, innnmx BARS Attorney and Counselor at Law _ Of C¤¤¤¤¤|
2920 N. Green Valley Parkway, Suite 421 iu; a
Cgggmsigff Henderson, Nevada 89014 NEVADA www Y0 ARS
Telephone (702) 433-8780
Telecopier (702) 433-8295 _
email: [email protected]
June 24, 2002 ·
Via Facsimile & U.S. Mail I _ -
(913) 268-8898 . A
Jeffrey D. Zimmerman, Esq. i
5819 Nieman Road _
Shawnee, Kansas 66203 ° ° . · _
Re: Cathleen Channel, et al v. Home Mortgage, Inc. ‘ · V ·
Dear Mr. Zimmemianz _ l _
I have been retained to represent Cathleen Channel, Theresa Wharry, Stacie Hanson and Monique
Nichols with regard to unpaid and outstanding commissionincome due to each one of my respective clients. I
believe you are aware of the commission income due to these individuals. Also, Ibelieve you have given my
clients, on at least one occasion, your assurance they would be paid their commissions. However, and despite
their demands and your assurances, they have not received the monies due and owing to them. My clients are
due commission income as follows: . _ _ D , _
1. Cathleen Channel - $33,219.90 j
2. Theresa Wharry - $18,547.03 ‘ ‘
3. Stacie Hanson - $9,81 1.25
4. Monique Nichols - $15,835.33
This will be my one and final letter of demand to your client for payment of the aforementioned
commission income. If my clients do not receive theirrespective commission payments, in fiill, consistent with
the aforementioned dollar figures by a date of no later than July 10, 2002, I have been instructed to tile a lawsuit
on their behalves in a court of competent jurisdiction in Phoenix, Arizona. We have already arranged for an
attomey in Phoenix to serve as our local counsel. I trust your client will do the right thing and pay my clients
the commission income due to them and avoid unnecessary litigation. Finally, I would respectfully request that
neither you nor your clients have any further contact with my clients, except for forwarding their commission
checks to them. Any and all fixture communication/correspondence, besides the forwarding of commission
checks, should be addressed to my attention at my law offices. .
l Veryltruly yours, ·
PNC:ceg
cc: Cathleen Channel
Theresa Wharry e , _
Stacie Hanson
Monique Nichols 1
V Case 2:03-cv-001 00-ROS-IVI EA Document 114-7 Filed 01/12/2007 Page 1 of 1

Case 2:03-cv-00100-ROS-MEA

Document 114-7

Filed 01/12/2007

Page 1 of 1