Free Statement - District Court of Arizona - Arizona

UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
CASE NO. CIV 03 2353-PHX-DGC
CENTURY 21 REAL ESTATE CORPORATION,
DARYUSH B. MOTLAGH AND JANE DOE MOTLAGH, HUSBAND AND WIFE; I
INTEGRITY ASSURANCE, ·

EXHIBIT TO CENTURY 21 REAL ESTATE CORPORATION’S: (1) RENEWED
MOTION FOR SUMMARY JUDGMENT ON ITS BREACH OF CONTRACT
AND UNJUST ENRICHMENT CLAIMS; AND (2) MOTION FOR SUMMARY
JUDGMENT ON COUNTERCLAIMS

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Case 2:03-cv-02353-DGC Document 78-15 Filed O7/O7/2006 Page 1 of 2
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Real Estate Corporation
10 Sylvan Way
Parsippany, New Jersey 07054
Business (973) 428-9700 , l
_ Fax (973) 496-7090
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VIA MRBORNE EXPRESS _
November 17, 1998 '
Daryush Motiagh
CENTURY 21 Assurance Realty
14175 W. Indian School Road
Goodyear, AZ 85338
. Dear Mr. Motlagh: -
This letter confirms our conversation today. The total. outstanding amount owed to Century 21 Real Estate . -
Corporation ("CEN'l'URY21") is $18,533.08 which represents NAF of $2,458.00 and Accounts Receivable balances Z. i
of $16,065.08. We will agree to the following terms and conditions: ' y·
- l • You make two $500.00 good faith payments to be received on or before November 23, 1998 and December 31, l
1998 respectively. Please send payment to me at the above address.
• You make $1,500.00 monthly payments to be received January 30,1999 through November 30, 1999. The l
balance of $1,033.08 to be paid on or before December 30, 1999. - i
• You agree to report and pay ali 1998 closed service fee transactions by January 30, 1999. i
• You agree to pay current _NAF and accounts receivable invoices timely. -
• You agree to be personally liable for all payments underthis plan. J
• After receipt of the good faith payment, a formal payment plan will be prepared for your signature. ‘ i
A R Please be reminded that the above amount does not include any future audit tindings covering the period through —
the date of this letter. Of course, this payment arrangement will be revised to include any unreported and unpaid {
T closed senrice fee transactions that might be found pursuant to an audit. i
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Please acknowledge your agreement with the foregoing, including your agreement that the foregoing amounts are i
due and payable to Century 21 by signing below. Of course, please call me with any questions you may have. {
This letter is written without prejudice and is not a waiver of any rights or remedies that Century 21 Real Estate
Corporation may have in law or in equity. . i
Sincerely, _ ` 0 Agreed and accepted:
‘ ‘ D as Carol: r
Manager of Financial Services Daryush Motlagh — Broker . _
(973)-496-7094 CENTURY 21 Assurance Realty r _
cc: K. De Berry ` l l
T. i—lasei__ _ E , Daryush lvlotiagh — Individuaily -
A Cendant Company C21-00195 - r I
_ I . { ( Li SJ _:
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Case 2:03-cv-02353-DGC

Document 78-15

Filed 07/07/2006

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Case 2:03-cv-02353-DGC

Document 78-15

Filed 07/07/2006

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