Incentive Capital v. Camelot Entertainment Group et al

Filing 125

WRIT of Execution issued. Signed by Judge Waddoups on 11/28/11. (jmr)

Download PDF
Joseph G. Pia (9945) Nathan S. Dorius (8977) PIA ANDERSON DORIUS REYNARD & MOSS 222 South Main Street, Suite 1800 Salt Lake City, Utah 84101 Telephone: (801) 350-9000 Facsimile: (801) 950-9010 E-mail: Attorneys for Plaintiffs IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTRAL DIVISION INCENTIVE CAPITAL, LLC, a Utah Limited Liability Company, WRIT OF EXECUTION Plaintiff, Civil No. 2:11-cv-00288 v. Judge Clark Waddoups CAMELOT ENTERTAINMENT GROUP, INC., a Delaware Corporation; CAMELOT FILM GROUP, INC., a Nevada Corporation; CAMELOT DISTRIBUTION GROUP, INC., a Nevada Corporation, ROBERT P. ATWELL, an individual; JAMIE R. THOMPSON, an individual; STEVEN ISTOCK, an individual; TED BAER, an individual; PETER JAROWEY, an individual, Defendants. 6 THE UNITED STATES OF AMERICA to the Constable, Sheriff, or other enforcement person, agency, or entity: 1. An application for Writ of Execution has been entered jointly by the parties Incentive Capital, LLC (“Plaintiff” or “Incentive”) and Defendants Camelot Entertainment Group, Inc., Camelot Film Group, Inc., Camelot Distribution Group Inc. (collectively, the “Camelot Defendants”). 2. The Liberation Film Library, which refers solely to those titles listed on Exhibit 2 of the Settlement Agreement, is the property of Incentive pursuant to the Settlement Agreement entered into by Camelot and Incentive; whereby, Camelot transferred all ownership in the Liberation Film Library and all elements related thereto to Incentive. 3. You are directed to enter into the Camelot Defendants’ premises and/or any premise utilized by the Camelot Defendants for the storage of business records and tangible materials solely related to the Liberation Film Library and/or any physical item associated with the Liberation Film Library and to take immediate possession of such materials (“Materials”) for and on behalf of Incentive. 4. The “Materials” include without limitation any materials relative to the Liberation Film Library comprising approximately 888 film, television, and other media titles and all tangible elements thereof, such as: a. Camelot’s data bank stored on its computers and servers and elsewhere, including but not limited to copyright information, creditor lists, websites, copyrights, trademarks, registration marks, patents, advertising and marketing graphics and materials, logos, deals and contracts by library titles and 7 distribution agreements, DVD inventory reports (including where available the location of any physical materials); b. Film elements and materials in storage, software related in any way to the Liberation Film Library that Camelot has access to or is in the possession of; c. The website relating to the Liberation Film Library, website scripts, database and efiles, current keyword rankings, CSS script functions, master artwork files in any format, title descriptions, digital audio/visual files, and any online materials solely related in any way to the Liberation Film Library; d. Any and all contracts, contract rights, deals, and correspondence related to the Liberation Film Library; e. Any and all money, bank accounts, and safety deposit boxes relative to proceeds held in the name of or for the benefit of Incentive or Camelot relative solely to the Liberation Film Library. 5. You are to return this Writ within 10 days after receiving it, with a signed account of your actions in executing this Writ. 6. The Writ of Execution is intended to survive the dismissal of this case with prejudice because it arises out of the parties Settlement Agreement. 28th November 11 Dated this __ day of ________, 20___ UTAH FEDERAL DISTRICT COURT _________________________ Hon. Judge Waddoups, designee, or Clerk of the Court 8

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?