UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
CASE NO. CIV 03 2353-PHX-DGC A
CENTURY 21 REAL ESTATE CORPORATION,
1
DARYUSH B. MOTLAGH AND JANE DOE MOTLAGH, HUSBAND AND WIFE;
INTEGRITY ASSURANCE, L
EXHIBIT TO CENTURY 21 REAL ESTATE CORPORATION’S: (1) RENEWED aL
MOTION FOR SUMMARY JUDGMENT ON ITS BREACH OF CONTRACT
AND UNJUST ENRICHMENT CLAIMS; AND (2) MOTION FOR SUMMARY
JUDGMENT ON COUNTERCLAIMS
EXHIBIT 14 1
1.
n
.
§
Case 2:03-cv-02353-DGC Document 78-19 Filed O7/O7/2006 ‘ Page 1 of 3 I
i ,
§ .
2* r y}? ; -A--lk _ 7 · -
¤ . _. fi` Q ._ _ ' .
.-··- Fleal Estate Corporation _ ‘ _
- 5 10 Sylvan Way · _
‘ Parsippany, New Jersey 07054 · ` »
. Business (800) 811-2305
Fax (97:2) 496-7090 ‘ g _ _
.VlA AIRBORNE B
Daryush Nlotlagh ’ . . . l .
CENTURY 21 Assurance Realty
‘ y .14175 W. Indian School Road g
- Bypass Suite A-7 l
Goodyear, AZ 85338
- Re: Company ID No. 221078-0001 - Goodyear, AZ I '
· Dear Mr. Motlagh: - A ·
. 0 l
-‘ This letter will coniinn the tenns of the payment plan which has been agreed upon between CENTURY
21 Assurance Realty (the “Franchisee") and Century 21 Real Estate Corporation, (Company`) relating to . ;
g. amounts owed by Franchisee to Company under its Century 21® Real Estate Franchise Agreement (the l
a "Agreement"}. The outstanding balance on Franchisee account which is subject to this payment plan is ·
$42,733.86 which represents all delinquent fees and charges owed by Franchisee through and including
04106/00. This amount does not include any balances subsequent to that date, and balances found
pursuant to any future audit covering this period. An analysis of this liability with supporting detail is ` l
_ attached for your reference. After your review, please contact me ifyou _believe any amounts are
incorrect. By signing below you, acknowledge that youwill be individually liable for all amounts due under
the terms of this payment plan. _
The payment plan will be as follows: ._ `
T MONTHLY PAYMENT MONTHLY
DUE DATE PAYMENT AMOUNT
June 1, 2000 —- August 1, 2000 $500.00 +_Current Fees (as delined below) ` 4
September 1, 2000 $41,233-86 + Current Fees · l
i.
" All monthly payments must be in our oflice on or before the above-specitied dates. Ii payment is
j not received by the 'due dates", this plan will-become null and void and the entire outstanding balance will
immediately become due in full. The continued participation of your oltice and agents in the CENTURY ·
21 Awards Program is contingent upon your honoring the temts and conditions of this payment plan.
Additionally, this payment plan must be paid in full on or before the CENTURY 21 Cash Incentive Bonus l
A issuance date to be eligible to receive any CENTURY 21 Cash Incentive Bonus. I l
l ‘ Please be reminded that in order for your CENTURY 21 Oflice to be in good standing, Franchises must g_
pay all current fees due under the Agreement including, but, not limited to, royalty fees, minimum royalty
g ies, National Advertising Fund tees, balance due on any and all promissory notes andlor expansion
` notes, tinance charges, miscellaneous invoices, and any other fees, in addition to the monthly installment
El, , f- as outlined in the above plan. Y
\ 1 C2l~OO048
n 1tl¤5U'1°lE EIS n n 0001t10l00lW seuogrvs in- ‘
n Haw 3;;* lti50i+'i2-6t5 S"*°$·EllP WE?/Oli g Wil-L 1 Pr Z‘l°â€â€Â°S“'°°“°0ssas
it Billllag ,_ . . Film _ °“¤·e.l¤ .
asé 2?6I§-N-02353-DGC Document 7g-Tl°9 Filed O7/O7/2006 pag . — _
’ — ‘ i
A Apni 21,2ooo ` A t . l ` `
‘ * l CENTURY 21 Assurance Realty
Wnh the retum of the signed copy of this letter Franchisee agrees, on behalf of itsetf, its partners,
officers, employees, directors, shareholders and any Guarantor(s) of the Agreement, and the
` successors and assigns of eacl1 of them, hereby release and hold bam1less the Company, its
officers, employees, agents, directors, shareholders, and the successors and assigns of all of
. g them from any and ali liability cost or expense, arising from any claims, or causes of action which
Franchisee has or may have against Company under the Agreement as of this date hereof.
This payment plan shall not be assignable by Franchises or Daryush Motlagh, individually without
‘ the prior written consent of Century 21. y
A All PAYMENTS and correspondence shouid be sent via OVERNIGHT MAIL to the following:
l , y Century 21_ Real Estate Corporation _-
10 Sylvan Way R §
_ Parsippany, NJ 07054 §
A Attn: Elise Zapka -
_ Please acknowledge acceptance of this letter agreement by signing where indicated below and
retuming one original to me with your payment. · - Q
Very truly yours,
’ · E.
QQ/L<2b me/r l
PQ Elise Zapka
P ’ Financial Services U i
A Agreed to: - R
CENTURY 21 Assurance Realty ‘ ]
y By: ‘
- Daryush Motlagh - Owner p
A Agreed to: _
By: p
Daryush lvlotiagh - individually -
Attachments
. _ l
cc: K. Link ` ‘
l C21-00049
Case 2:O3—cv-02353-DGC Document 78-19 Filed O7/O7/2006 Page 3 of 3 i
Case 2:03-cv-02353-DGC
Document 78-19
Filed 07/07/2006
Page 1 of 3
Case 2:03-cv-02353-DGC
Document 78-19
Filed 07/07/2006
Page 2 of 3
Case 2:03-cv-02353-DGC
Document 78-19
Filed 07/07/2006
Page 3 of 3
United States Free Forms
Canada Free Forms
United Kingdom Free Forms
Australia Free Forms