Free Notice (Other) - District Court of Colorado - Colorado

Case 1:03-cv-01411-PSF-MJW

Document 73

Filed 10/03/2005

Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 03-CV-01411-PSF-MJW CYNTHIA A APA, Plaintiff, v. QWEST CORPORATION., Defendant. ______________________________________________________________________________ NOTICE OF ATTORNEY'S LIEN COMES NOW John W. McKendree, former counsel of record for the Plaintiff, Cynthia Apa, and pursuant to C.R.S. 12-5-119, 1973, as amended, asserts an attorney's lien on the Plaintiff's interests in and to the following property: Proceeds from the litigation or settlement of above-entitled case. This lien is for attorney's costs and expenses due and owing in the amount of $ 4645.48 plus interest pursuant to a Contingent Fee, costs and expenses only, reduced hourly, agreement entered into between counsel and Cynthia Apa on July 8, 2002, for representation in the aboveentitled matter. This lien is derived from the representation by counsel of Cynthia Apa from July 8, 2002 to September 13, 2005, during which the above described property was an issue and in which action Plaintiff have a 100% interest in said property. Cynthia Apa's former counsel, John W. McKendree, is allowed such a lien because he assisted Cynthia Apa in obtaining any judgment in whole or part in the above-entitled case. In re Forrest A. Health Co., 159 F.Supp.

Case 1:03-cv-01411-PSF-MJW

Document 73

Filed 10/03/2005

Page 2 of 3

632 (D. Colo.), aff'd sub nom. Donaldson v. Gaudio, 260 F.2d 333 (10th Cir. 1958). Dated this 1st day of October, 2005. Respectfully Submitted, _________________________________ John W. McKendree, #1209 Prior Attorney for Plaintiff 1244 Grant St Denver, CO 80203 303/861-8906 STATE OF COLORADO COUNTY OF DENVER ) )ss. )

John W. McKendree, being first duly sworn upon oath, states that the contents of this Notice of Attorney's Lien are true and correct. /s/ John W. McKendree ________________________________ John W. McKendree Subscribed and sworn to before me this 1st day of October, 2005. /s/ Kelly L. Dyche ________________________________ Notary Public My commission expires: 09/26/2006

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Case 1:03-cv-01411-PSF-MJW

Document 73

Filed 10/03/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 1st day of October 2005, a true and exact copy of the foregoing NOTICE OF ATTORNEY'S LIEN was served upon the court via EFC and served upon the parties via e-mail or deposited in the U.S. mail, first- class, postage prepaid addressed as follows: J. Mark Baird 2036 East 17th Ave. Denver, Colorado 80206 [email protected] Camille Torres, Esq. Qwest Corporation 1801 California - 9th floor Denver, Colorado 80202 [email protected] Cynthia Apa 7664 Reed Street Arvada CO 80003

s/Kelly L. Dyche-Oberg __________________________

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