HomeMy WebLinkAbout875637 LJI'~C, OI,,~I,I """' '," '
'" C, OU~,f I'~ CLERK
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BAILEY DOTSON, )
) U.S. DIS1RICT COURT
Plaintiff )
) Docket No. 00CV 165D
V. ' )
)
GENE VE~ON, . )
)
Defendant. )
NOTICE OF CLAIM OF LIEN
TO:'BAILEY DOTSON AND GENE VERNON
YOU ARE HEREBY NOTIFIED that The Fermelia Law Office, P. C., of 217 West 18th
Street, City of Cheyenne, CoUnty of Laramie, State of Wyoming 82001, telephone number of (307)
635-6100, claims a lien on that real property described as:
Lots 9, 22, 25; 27, 28, 29, 30, 31 8c 34, Greys River Village Second Addition to the Town
of Alpine, within the NW 1/4 SW 1/4 of Section 28 and NE 1/4 SE 1/4 of Section 29, T37N,
R118W, according to that plat filed in the Office of County Clerk, Lincoln County,
Wyoming, subject to reservations and restrictions contained in the United States Patent and
to easements and rights-of-way of record or in use together with all improvements and
appurtenances thereon,
(hereinafter"Real Property") for attorney's fees and costs and interest accrued thereon on behalf of
Gene Vernon in the above entitled action at the request of Gene Vernon and pursuant to an Attorney-
.. Client Renewing Retainer Fee Agreement (hereinafter "Fee Agreement") executed by Gene Vernon
and The Fermelia Law Office, P. C. on or about October 6, 2000 which is incorporated herein as if
fully set forth; that demand for payment for such attorney's fees and costs and interest accrued
thereon on behalf of Gene Vernon in the above entitled action has been previously made upon Gene
Vernon' by The Fermelia Law Office, P. C.; that Real Property 'constitaYesc~r~9~V~i'y..of Gene
~' ' ~3.¥ ~ "
...,?;,....,.,. ~ .., q'., ,,..
Vernon pursuant to a Settlement Agreement and Release executed and entered into on or about July
24, 2001 by and between the parties in the above entitled action; the amount Claimant demands for
said attorney's fees and costs and interest accrued thereon on behalf of Gene Vernon in the above
entitled action is $13,037.07; that no part thereof has been paid and there is now due and remaining
thereon, after deducting all credits and offsets, the sum of$13,037.07, plus any additional attorney's
fees and costs incurred and accruing:, interest at the rate of ten percent (10%) per annum from that
date identified below in which ampunt Claimant claims a lien on said Real Property Pursuant to
Wyo. Stat. § 29-1-102 and the aforementioned Fee Agreement.
DATED thisg-~4/'-day of August, 2001.
THE FERMELIA LAW OFFICE, P. C.,
Claimant
By: _
MatthewC'J:-~rrfielia, President
217 West 18th Street
Cheyenne, WY 82002
(307) 635-6100
THE FERMELIA LAW OFFICE, P.C.
217 WEST 18TM STREET
CHEYENNE, WY 82001
TELE: (307) 635-6100
FAX: (307) 635-4506
E-MAIL: FERMELIALAW{~USWEST.NET Page 2 of 3
,.-, 025
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Notice of Claim of Lien in the
above-entitled action was served via United States Mail as idenSfied upon the following parties in
interest this~Q~"-day of August, 2001:
Gene Vernon . [.___] U.S. Mail Postage Prepaid
3930 Indian Way [ ] Federal Express
Santa Ynez~ CA 93460 [ ] Personal Hand-Delivered
[ ] Facsimile
LX _] Certified Return Receipt
Requested U.S. Mail
Postage Prepaid
Kevin Keller [ ] U.S. Mail Postage-Prepaid
G. Kevin Keller, Attorney at Law', P.C. [ ] Federal Express
Attorneys for Bailey Dotson [ ] Personal Hand-Delivered
1807 Capitol Avenue, Suite 30 [ ] Facsimile
Cheyenne, WY 82001 [_X J Certified Return Receipt
Requested U.S. Mail
Postage Prepaid
Richard Mincer [_X_] U.S. Mail Postage Prepaid
Hirst & Applegate, P.C. [ ] Federal Express
1720 Carey Avenue, Suite 200 [ ] Personal Hand-Delivered
P. O. Box 1083 [ ] FacSimile
Cheyenne, WY 82003-1083 [ ] Certified Return Receipt
Requested U.S. Mail
Postage Prepaid
THE FERMELIA LAW OFFICE, P.C.
217 WEST 18TM STREET
CHEYENNE, W'Y 82001
TELE: (307) 635-6t00
FAX: (307) 635-4506
E-M^a.: FEa~.r.I^~.^W@USWEST.N~.T Page 3 of 3