United States District Court, D. Nevada
MILLENNIUM DRILLING CO., INC., a Delaware Corporation, Plaintiffs,
BEVERLY HOUSE-MYERS, BEVERLY HOUSE-MYERS REVOCABLE TRUST, GRACE MAE PROPERTIES, LLC, HAMRICK TRUST, ROBERT H. HAMRICK, MOLLY KAY HAMRICK, TRUSTEES, Defendants MOLLY HAMRICK, BEVERLY HOUSE-MYERS, R&M HAMRICK FAMILY TRUST, Third-Party Plaintiffs,
JONATHAN FELDMAN, MONTCALM, LLC, PATRIOT EXPLORATION COMPANY, LLC, CARTER HENSON, JR., MATTHEW BARNES, ROBERT HOLT, ELIZABETH HOLT, and SCHAIN, LEIFER, GURALNICK, Third-Party Defendants.
Douglas D. Gerrard, Esq. Nevada Bar No. 4613 John M.
Langeveld, Esq. Nevada Bar No. 11628 Gerrard Cox Larsen
Attorneys for R&M Hamrick Family Trust Robert H. Hamrick,
Trustee and Molly Kay Hamrick, Trustee
W. Davis, II, Esq. Nevada Bar No. 2531 Jason P. Weiland, Esq.
Nevada Bar No. 12127 Howard & Howard Attorneys, PLLC
Attorneys for Millennium Drilling Co., Inc., Jonathan Feldman
and Patriot Exploration Company, LLC
Fleischman, Esq. Fleischman Law Firm PLLC Attorneys for
Millennium Drilling Co., Inc., Jonathan Feldman and Patriot
Exploration Company, LLC
STIPULATION AND [PROPOSED] ORDER RE: PARTIAL
SATISFACTION OF JUDGMENT
NOW Defendant R&M Hamrick Family Trust
(“Trust”), by and through its attorneys, Gerrard
Cox Larsen and Plaintiff, Millennium Drilling Co., Inc.
(“Millennium”), by and through its attorneys,
Fleischman Law Firm, PLLC and Howard & Howard Attorneys,
PLLC and hereby submit their Stipulation and Proposed Order
Re: Partial Satisfaction of Judgment, as follows:
or about November 22, 2016, a Judgment in a Civil Case was
filed in favor of Millennium and against the Trust, in the
amount of $1, 411, 300.00 (“Judgment”) [ECF 328];
or about July 6, 2017, a Writ of Execution was issued out of
the United States District Court for the District of Nevada,
as requested by Millennium, seeking to execute on real
property owned by the Trust;
or about October 6, 2017, a Claim of Exemption from Execution
and Request for Hearing was filed by the Trust [ECF 405],
wherein real property owned by the Trust was claimed as
exempt, to the extent authorized by law, from
Millennium's attempt to execute, identified as follows:
10316 Summit Canyon Drive Las Vegas, NV 89144
LOT 16 IN BLOCK 1 OF STAR CANYON AS SHOWN BY MAP THEREOF ON
FILE IN BOOK 81 OF PLATS, PAGE 29 IN THE OFFICE OF THE COUNTY
RECORDER OF CLARK COUNTY, NEVADA.
(hereinafter the “Summit Canyon Residence”).
Additionally, the Trust also owns that certain real ...